Meaning of "initial" recovery plan

The "initial" recovery plan refers to the current available version of the recovery plan, which can be either the recovery plan "as last amended" in case it has been updated already or the plan that has not been updated yet; that is the reason for the cross reference to Article 5(2) under Article 27(1)(a) of the BRRD. This question goes beyond matters of consistent and effective application of the regulatory framework. A Directorate General of the Commission ( Directorate General Financial Stability, Financial Services and Capital Markets Union) prepared the answer, albeit that only the Court of Justice of the European Union can provide definitive interpretations of EU legislation. This is an unofficial opinion of that Directorate General, which the European Banking Authority publishes on its behalf. The answers are not binding on the European Commission as an institution. You should be aware that the European Commission could adopt a position different from the one expressed in such Q&As, for instance in infringement proceedings or after a detailed examination of a specific case or on the basis of any new legal or factual elements that may have been brought to its attention.