EBA · 2022_6428 Rejected question

Reporting of critical external providers in template Z 08.00

Regulation
Directive 2014/59/EU (BRRD)
Article
11, para. 3
Topic
BRRD Reporting
Submitted by
Credit institution
Submitted
2022-04-21
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Question

Does a critical external / third-party provider to a service provider which is not indicated as relevant and listed in template Z 01.00 have to be reported in template Z 08.00?

Background

In line with Article 4(2), points (a) and (h) of Implementing Regulation (EU) 2018/1624, our understanding is that critical external/third party-providers to an institution (listed in Z 01.00) have to be reported in Z 08.00. Whereby receiving service providers not named in Z 01.00 should not report their critical external/third party providers in Z 08.00, i.e. critical external services to the institution (institution is named in Z 01.00) are to be reported in Z 08.00, critical external services to a service provider that is not listed in Z 01.00 does not have to be reported in Z 08.00. This understanding is also reflecting that an unregulated service provider does not have critical functions, but Z 08.00 is asking for the related critical functions.
No answer published yet.

Original source: European Banking Authority, Q&A ID 2022_6428

This Q&A is published by European Banking Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

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