EBA · 2026_7729 Final Q&A

Z 09.01 (FMI 1) - Reporting of FMI services related to payment systems under EBA 4.2.

Regulation
Directive 2014/59/EU (BRRD)
Article
11, para. 3
Topic
BRRD Reporting
Submitted by
Resolution authority
Submitted
2026-02-20
Answered
2026-04-03
Answer provided by
ESAs (EBA, ESMA, EIOPA)
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Question

According to the Annex for IT Solutions related to the ITS on resolution reporting, entities should be allowed to report “Payment systems” as a type of system in Z 09.01, c0040. However, such possibility is not allowed under the DPM table layout and data point categorization (i.e. the annotated tables). This raises a question on how should entities ensure compliance with the ITS.

Background

According to Article 7(1) of Commission Implementing Regulation (EU) 2025/2303 ("CIR on resolution planning reporting"), reporting entities shall submit the information referred to in Articles 2 to 5, as specified in the templates set out in Annex I of the CIR on resolution planning reporting, respecting the data point definitions included in the single data point model referred to in Annex II and the validation rules referred to in Annex III. However, in the case of the data point with reference Z 09.01, c0040 (i.e. the 'System type' to be reported in the template on FMI Services - Providers and Users (FMI 1)) the taxonomy of the annotated tables does not allow to provide the information as requested in the annex for IT solutions. In particular, the option 'Payment systems' is not available in the picklist/menu related to the relevant data point. Against this background, guidance is requested on how to report payment systems.

Answer

In table  Z09.01 , where the type of system providing services to the user is ‘Payment systems’, the option  ‘Not applicable’  should be chosen in the picklist available on  column c0040 . The value  ‘Payment systems’  should then be provided in  column c0220  (on  Services provided by FMI/Intermediary ).  When the reported FMI correspond to a payment system, the reporting entity should  complete all relevant fields in the template  (e.g., ‘FMI name’, ‘FMI code’, etc.),  as if the option ‘Payment systems’ had been available . As a result, the warning related to  validation rule v90347  should be  disregarded  when the warning is triggered by the payment system nature of the FMI.

Original source: European Banking Authority, Q&A ID 2026_7729

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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