EBA · 2026_7735 Rejected question

Template Z 01.02 Resolution Planning – Uniqueness Requirement for Column 0020

Regulation
Directive 2014/59/EU (BRRD)
Article
1
Topic
BRRD Reporting
Submitted by
Credit institution
Submitted
2026-02-26
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Question

In template Z01.02 in column 0020 the unique identifier of the legal entity or investor referred in column 0010 should be reported. In our ownership structure, several investors hold participations in multiple investee entities, meaning the same investor appears in multiple rows of Template Z 01.02. Because the identifier in Column 0020 must consistently represent the same legal entity, it must be repeated across those rows. This, however, conflicts with the requirement that Column 0020 contain a unique value for each row.

Background

In the ownership structure template Z01.02 all the shareholders (or equivalent) of the group’s entities with more than 2% of share capital (or equivalent) or voting rights, and all the shareholdings (or equivalent) held by entities of the group shall be the listed.  Since one investor -being the parent entity of the group, can hold participations in multiple investees entities-being the subsidiaries, the same legal entity (investor) must be repeated across rows. Because the identifier in Column 0020 must contain a unique value for each row we are unable to report the total ownership structure.  We would greatly appreciate an answer to be able to report properly the ownership structure
No answer published yet.

Original source: European Banking Authority, Q&A ID 2026_7735

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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