This final report presents the implementing technical standards (ITS) on reporting for resolution planning, aiming to improve harmonization and simplification of reporting requirements. It emphasizes the importance of collecting accurate information for resolution authorities to develop effective resolution plans. The new ITS introduce modular reporting obligations and reduce overlaps with other reports while…
This document is the final report of the European Banking Authority (EBA) published in 2025, entitled "Final report on draft ITS on Resolution Planning reporting." It is a technical implementation standard (ITS) intended to specify procedures, forms, and standard templates for providing information necessary for the preparation of resolution plans for credit institutions and investment firms, in accordance with Directive 2014/59/EU (BRRD). The scope covers European financial institutions subject to resolution regulation, focusing on relevant entities within banking groups, including liquidation entities, over the period starting in 2026 with a first reference date of December 31, 2025. The document comprises 64 pages, of which approximately 39 pages were provided for this synthesis (p. 1-39).
The subject concerns the revision of the technical implementation standards (ITS) related to reporting for resolution planning of banks and investment firms in the European Union. This revision aims to harmonize, simplify, and make more proportionate the data collection framework necessary for resolution authorities to develop resolution plans and assess the resolvability of institutions. The challenge is to avoid parallel data collections, eliminate redundancies, and improve the quality and use of collected data, taking into account recent developments in practices and regulatory requirements. The main findings are that since the last update in 2018, resolution authorities, notably the Single Resolution Board (SRB), have developed specific parallel data collections, creating inefficiencies and burdens for institutions. The new framework introduces a lower threshold for defining relevant legal entities (2% versus 5% previously), extends the scope to liquidation entities not subject to simplified obligations, and introduces a modular "core-plus-supplement" reporting to adapt obligations according to entity size and complexity. Granular reporting of liabilities is introduced to improve transparency and data quality on bail-inable debts, essential for resolution planning. Submission deadlines are split into two modules: first on March 31 for organizational data and liabilities, second on April 30 for critical functions, services, and FMIs, balancing authorities' needs and institution burden. Conclusions emphasize that these ITS will enable better harmonization and reduction of ad hoc collections while respecting proportionality. Recommendations focus on rapid adoption by the European Commission, publication of data models and validation rules, and operational implementation from 2026. This reform is considered beneficial for European financial stability despite increased compliance costs, offset by simplification and redundancy reduction (p. 3-5).
The document was developed to address the need to adapt the reporting framework for resolution planning of banks in the European Union, in compliance with Directive 2014/59/EU (BRRD). Since the initial implementation of the ITS in 2014-2015, then their update in 2018, resolution authorities have gained experience and identified new data needs, leading to parallel collections and redundancies, notably between the SRB and national authorities. The regulatory context has also evolved, with the introduction of the liquidation entity concept in Directive 2024/1174. The main objective is to harmonize and centralize reporting requirements, improve data quality and usefulness for planning and crisis preparedness, while respecting proportionality and limiting the burden on institutions. The scope covers banking and investment entities, banking groups, and liquidation entities, with particular attention to thresholds defining relevant entities and reporting modalities (p. 5-9).
- Harmonization and simplification: The report emphasizes the importance of avoiding parallel data collections, notably between the SRB and national authorities, by integrating requests into a single framework. The removal of redundant data with other regulatory reports (CoRep, FinRep, MREL-TLAC) is also implemented (p. 3, 8-9, 26-27).
- Proportionality and modularity: A modular "core-plus-supplement" model is introduced, allowing smaller or less complex entities to provide only a subset of data, while larger or more complex entities provide additional data. Liquidation entities not subject to simplified obligations have reduced requirements (p. 3-4, 18-20).
- Thresholds and entity scope: The threshold to define a relevant legal entity (RLE) is lowered from 5% to 2% of total risks, with an absolute threshold of 5 billion euros in assets. This extension aims to improve data coverage for public interest assessment and financial stability. Entities outside the banking union will likely see an increased scope (p. 9).
- Granular reporting of liabilities: Introduction of detailed reporting at contract level of intragroup liabilities, securities, deposits, secured financing, derivatives, enabling better analysis of bail-inability, insolvency ranks, maturities, and MREL eligibility. This reporting applies to resolution entities and RLE institutions, exempting liquidation entities and those under simplified obligations (p. 17-20).
- Critical functions and essential services: Extension of data collected on critical economic functions, including detailed impact and substitutability analysis, with specific quantitative indicators per function (deposits, loans, payments, capital markets, wholesale funding). Addition of the onboarding capacity concept to assess resilience (p. 13-15).
- Relevant services and financial market infrastructures (FMIs): Extension of reporting to essential services linked to main business lines, with finer identification of services, roles, and operational assets. Addition of information on FMI contracts, notional derivatives, initial margins, and contract resilience, as well as a table on CCP alternatives in case of resolution (p. 15-16).
- Submission dates: Adoption of a two-step schedule for data submission, with a first module (organizational structure, liabilities) on March 31 and a second (critical functions, services, FMIs) on April 30, balancing authorities’ needs and institutions’ constraints (p. 4, 20-21).
- Cooperation between authorities: Maintenance and strengthening of cooperation between competent and resolution authorities to avoid duplicate requests and enable sharing of already collected data (p. 29-30).
- Cost and impact: Although the revision leads to an increase in data to be provided (about 1500 additional data points), simplification, removal of redundancies, and modularity aim to limit the burden. The impact report concludes that benefits in quality and harmonization outweigh costs (p. 18-20, 31-33).
- Public consultation: The majority of respondents support the revision and harmonization, while expressing concerns about implementation costs and tight deadlines. The EBA considered this feedback by adjusting deadlines and clarifying obligations (p. 34-39).
- Established facts:
- The current reporting framework for resolution planning is fragmented, with parallel collections between the SRB and national authorities (p. 3, 6).
- The scope of concerned entities is expanded, notably by lowering the RLE threshold to 2% and including liquidation entities not subject to simplified obligations (p. 9).
- The introduction of granular liability reporting is a major advance for data quality (p. 17).
- Reporting modularity allows adapting the burden according to size and complexity (p. 19).
- Assumptions:
- Harmonization and removal of redundancies will reduce overall burden despite increased data requested (p. 18).
- Entities outside the banking union will bear increased burden due to scope expansion (p. 9).
- Interpretations:
- The ITS revision is necessary to reflect regulatory and practical developments and improve crisis preparedness (p. 5).
- Increased cooperation between authorities is key to avoid duplicate requests and improve efficiency (p. 29).
- Uncertainties:
- The precise impact on compliance costs remains to be measured, notably for small entities and outside the banking union (p. 34).
- Future ITS evolution will depend on the outcome of the RTS revision on resolution plan content (p. 8).
The EBA concludes that updating the ITS is essential to ensure harmonized, proportionate, and effective reporting for resolution planning in the European Union. The new framework will reduce ad hoc collections, improve data quality and comparability, and better meet resolution authorities’ needs. The main recommendations are:
- Rapid adoption by the European Commission of the revised ITS, with publication in the Official Journal of the European Union (p. 4, 22).
- Operational implementation from 2026, with a first reference date of December 31, 2025 (p. 4, 15).
- Publication by the EBA of data models (Data Point Model), XBRL taxonomy, and associated validation rules (p. 4).
- Maintenance of the proportionality principle via the core-plus-supplement modular model and removal of redundant data (p. 3-4, 18-20).
- Strengthening cooperation between competent and resolution authorities to avoid duplicate requests and facilitate data sharing (p. 29).
- Consideration of public consultation feedback, notably by adjusting reporting deadlines to limit institution burden (p. 34-39).
The EBA emphasizes that expected benefits in financial stability and resolution framework efficiency outweigh compliance costs, and that this framework will promote consistent and harmonized application across the Union.
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