EBA · 2025_7630 Final Q&A

Reporting Framework 4.2 - Z_09.02 - FMI services - Mapping to Critical and Essential FMIs

Regulation
Directive 2014/59/EU (BRRD)
Article
4
Topic
BRRD Reporting
Submitted by
Credit institution
Submitted
2025-11-20
Answered
2026-04-03
Answer provided by
ESAs (EBA, ESMA, EIOPA)

Question

How should the template z09.02 be filled?

Background

Based on the Reporting Framework 4.2 Instructions and Annotated Table Layout there can be several interpretation on how to fill the report Z09.02: unique row for every Connection-Country-CF, multiple CF linked to one connections in one cell, multiple CBLs in one cell, a unique row for every CBL. In addition, is not clear what to report if there are only Core Business lines and no Critical Functions since the critical function ID is a key value.

Answer

Template Z09.02 should be completed on the basis of the data reported in Z09.01. Column c0010 represents an identifier and should contain only one ID per row. This ID corresponds to the unique combination of user, FMI, system type and intermediary in Z09.01. Such a granular identification ensures that specific situations that may arise in resolution can be appropriately isolated and assessed.  A unique row for every Connection-Country-CF should be reported to meet the instructions. In template Z09.02, columns c0020 (Critical FMI) and c0050 (Essential FMI) are not mutually exclusive. Consequently, it is possible to report only core business lines where no critical functions have been identified. In line with the general instructions for the FMI Services templates (section II.25 of the Annex for IT solutions), the reporting of more than one item per field is only allowed for free form fields, not for pickup values. This is reflected in the DPM table layout and data point categorization (i.e. the annotated tables). Therefore, the reporting of multiple critical functions and core business lines in one cell is neither envisaged in the instructions or technically possible. In line with Q&A_ 2026_7730, should the instructions available in the DPM table layout and data point categorization (i.e. the annotated tables) prevent the submission of information on essential FMIs which are not critical, the reporting entity shall limit the scope of the reporting to critical FMIs and FMIs that are both critical and essential — until the relevant misalignment or contradiction is duly corrected or clarified, in upcoming technical packages.

Original source: European Banking Authority, Q&A ID 2025_7630

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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