EBA · 2026_7739 Final Q&A

II.29 Z 09.04 - FMI Services – CCPs – Alternative Providers (FMI 4)

Regulation
Directive 2014/59/EU (BRRD)
Article
Z 09.04 FMI 4
Topic
BRRD Reporting
Submitted by
Credit institution
Submitted
2026-03-04
Answered
2026-04-30
Answer provided by
ESAs (EBA, ESMA, EIOPA)

Question

According to c0050 "ID alternative provider" definition it looks like the entity should only report Alternative Provider when these providers are already reported in Z09.01. In the case an entity has a contingent contract of substitution with an alternative provider which currently doesn't provide any services to the entity, should the entity report this alternative provider? In affirmative case, which c0050 ID should we provide?

Background

Columns  Instructions  0010 ID representing combination of user, FMI, system type and intermediary Identifier of the CCP as provided in Z 09.01, column 0010.  Only report for CCPs accessed either directly or indirectly. Report all accesses to CCPs. 0020 Product Type Product type covered by the clearing agreement. Report at appropriate level of granularity needed for the substitutability analysis. 0030 Substitutability Y/N Ability of User to replace the clearing service provider in Z 09.01 column 0020 with an alternative FMI/intermediary with which it has a contractual relationship at the reporting date. . ‘Yes’ if substitution is possible ‘No’ if substitution is not possible   0040 Alternative Provider Name of FMI/intermediary identified as potential substitute.  Report only if Z 09.04 column 0030 is Yes. 0050 ID alternative provider Unique ID representing combination of user, FMI, system type and intermediary of the Alternative Provider with which the User has an established contractual relationship as reported in Z 09.01 column 0010.  Report only if Z 09.04 column 0030 is Yes.

Answer

According to the instructions of the Annex on IT solutions, template Z_09.04 should be filled in with regard to alternative providers that are CCPs.   Alternative Providers must be reported in Z 09.01 only if there is an established contractual relationship with them and, in line with the instructions in c0020 “Entity name”, the service is used.   Should the reporting entity not have an established contractual relationship with the alternative provider and should it not use the service, the alternative provider does not need to reported in Z 09.01 and Z 09.04.

Original source: European Banking Authority, Q&A ID 2026_7739

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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