EBA · 2026_7781 Final Q&A

The question pertains to resolution template Z.07.01, in which deposits are evaluated to determine whether they should be classified as a CEF.

Regulation
Directive 2014/59/EU (BRRD)
Article
Annex
Topic
Recovery plans
Submitted by
Credit institution
Submitted
2026-03-18
Answered
2026-06-26
Answer provided by
ESAs (EBA, ESMA, EIOPA)
More Q&As on this regulation →

Question

In column 0035 of template Z.07.01, where the amount of uncovered deposits must be reported, should the amount provided be the portion exceeding €100,000 per deposit, or the portion exceeding €100,000 per depositor?

Background

Initially, we believed that the correct way to report this data was by indicating the amount exceeding €100,000 per depositor, aggregating all deposits held by a single depositor. However, after reviewing the instructions provided by the EBA, we noted the following: “Carrying amount (including accrued interest) of deposits accepted with the balance of their account higher than €100,000. Only the amount exceeding €100,000 is to be reported.” By “deposits accepted,” we are unsure whether we should report the excess amount for each individual deposit, regardless of whether a depositor holds multiple deposits with the bank.

Answer

The instructions are clear on the fact that the amount should be the excess over EUR 100,000 for each individual deposit.  However, the bank is correct on flagging that this approach does not represent the value of non-covered deposits (as for non-covered deposits the threshold should be set at EUR 100,000 per depositor, rather than per deposit).  This will be reviewed in an upcoming review of the instructions to clarify that it refers to the coverage of the depositor.

Original source: European Banking Authority, Q&A ID 2026_7781

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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