Definition of ‘subordinated liabilities’ for FINREP reporting

What should be considered as ‘subordinated liabilities’’ for financial reporting purposes in FINREP template 8.2? Does definition of “subordinated liabilities” include also MREL instruments that do not qualify as Common Equity Tier 1, Additional Tier 1 or Tier 2 items meaning and have characteristics defined in the Article 72b(2) of CRR?

‘Subordinated liabilities’ are reported in FINREP template F 08.02. Instructions for FINREP published on the EBA website regarding definition of subordinated liabilities in Annex V, Part II, paragraph 100 refers to  Annex II (Table in Part 2) of the Regulation ECB/2013/33.  In the aforementioned Regulation ECB/2013/33, subordinated debt is defined  as a subsidiary claim on the issuing institution that can only be exercised after all claims with a higher status, e.g. deposits/loans, have been satisfied, giving them some of the characteristics of equity. It is further elaborated that for statistical purposes, subordinated debt is to be classified as either ‘loans’ or ‘debt securities’ according to the nature of the financial instrument.  However, it is not entirely clear what the term "characteristics of equity " in the above definition means. Does it also include instruments which do not qualify as Common Equity Tier 1, Additional Tier 1 or Tier 2, but meet the conditions set out in Article 72b(2) of CRR (i.e. MREL instruments).  Subordinated liabilities are defined also for to purpose of presentation in balance sheet in the Article 21 of Banking accounting directive 86/635/EEC as follows: “Liabilities: Item 8 — Subordinated liabilities Where it has been contractually agreed that, in the event of winding up or of bankruptcy, liabilities, whether or not evidenced by certificates, are to be repaid only after the claims of all other creditors have been met, the liabilities in question shall be shown under this item.”