Template Z08.01: Validation rules contradict ITS requirements

Do validation rules v6446_m and v6447_m for template Z 08.01 (Relevant services) correctly apply in all reporting situations, given that they enforce the condition {c0030} ≠ {c0050} (Service Recipient must differ from Service Provider)? Should these rules be amended or removed to correctly reflect cases of intra‑entity services, where both fields may legitimately contain the same entity name according to the IT Annex II: Instructions of EBA/ITS/2025/04?

During the review of the EBA validation rules for the Resolution Reporting framework, it was identified that the validation rules v6446_m and v6447_m applicable to template Z 08.01 appear inconsistent with the reporting logic defined in the IT Annex. Template Z 08.01 requires institutions to report relevant intra‑entity-, intra‑group-, and external services. The IT Annex explicitly states that, for intra‑entity services, the Service Recipient (column 0030) and the Service Provider (column 0050) may legitimately be identical. However: v6446_m enforces {c0030} ≠ {c0050} with severity = Error → This prevents submission of valid intra‑entity services and makes instruction‑compliant reporting impossible. v6447_m enforces the same condition {c0030} ≠ {c0050}, with severity = Warning → While not submission‑blocking, it still incorrectly flags valid intra‑entity service reporting as problematic. Both rules contradict the IT Annex, which clearly permits that c0030 and c0050 may be equal in intra‑entity cases. Consequently, these validation rules do not accurately capture the reporting logic intended for template Z 08.01 and lead to erroneous validation outcomes. Additionally, since v6446_m is classified as an Error, the rule is submission‑blocking. As a result, reports containing correct intra‑entity service data cannot be submitted while the rule remains unchanged. Given the upcoming submission deadline of 30 April 2026, a clarification or correction of the rule is urgently required to ensure timely and instruction‑compliant reporting.