EBA · 2025_7614 Final Q&A

Amount to be reported as MREL eligible amount and amount qualifying as Own Funds non-CET1 instruments, taking into account phase-out as applicable

Regulation
Directive 2014/59/EU (BRRD)
Article
Article 45b
Topic
Resolution plans
Submitted by
Consultancy firm
Submitted
2025-11-05
Answered
2026-04-03
Answer provided by
ESAs (EBA, ESMA, EIOPA)

Question

Could you please clarify whether in granular Resolution Plans reports (formerly SRB LDR) Z11.00, Z12.00, Z13.00 and Z14.00 the amount to be reported for Own Funds instruments (columns labelled Amount meeting the conditions for MREL eligibility  ) and columns reporting on the Amount qualifying as Own Funds is: the carrying value + accrued interest as recommended for the measurement of non-CET1 instruments or the outstanding amount (outstanding principal + accrued interest) as mentioned for the Amount meeting the conditions for MREL eligibility?  For the columns reporting Own Funds there is no specific guidance on the amount type to be reported other than the amount of the instrument qualifying as Own Funds.

Background

There is some uncertainty since EBA has published the Report on monitoring AT1 and MREL.pdf , where the recommendation is to measure non-CET1 instruments at carrying amount including accrued interest rather than outstanding amount, not to over- or underestimate the loss-absorption capacity of the total capital.

Answer

For the purpose of reporting the Granular Liability Data, the columns ‘Amount meeting the conditions for MREL eligibility’ (Z_11.00,c0175; Z_12.00,c0305; Z_13.00,c0115; Z_14.00,c0205) shall include the amount of the own funds and eligible liabilities counting towards the requirement set in accordance with Article 45(1) of the Directive 2014/59/EU. For that purpose, reporting entities should ensure that the methodology to determine the relevant amounts is aligned with the methodology followed to report the MREL amounts under the Commission Implementing Regulation (EU) 2021/763 of 23 April 2021 laying down implementing technical standards for the application of Regulation (EU) No 575/2013 of the European Parliament and of the Council and Directive 2014/59/EU of the European Parliament and of the Council with regard to the supervisory reporting and public disclosure of the minimum requirement for own funds and eligible liabilities.​  Regarding the reporting of own funds, reporting entities shall ensure that the methodology to determine the relevant amounts reported in columns ‘Amount Qualifying as Own Funds’ (Z_11.00,c0190; Z_12.00,c0320;Z_14.00,c0220; Z_17.00,c0140) is aligned with the methodology followed to report relevant own funds under the Commission Implementing Regulation (EU) 2021/451 of 17 December 2020 laying down implementing technical standards for the application of Regulation (EU) No 575/2013 of the European Parliament and of the Council with regard to supervisory reporting of institutions and repealing Implementing Regulation (EU) No 680/2014.

Original source: European Banking Authority, Q&A ID 2025_7614

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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