Z09.02 Requirement to Report CEF and Its Country When an FMI Only Supports a CBL

According to the EBA instructions, columns c0020, c0030, and c0040 are exclusively intended for essential FMIs (CEFs). However, in the template taxonomy, even when selecting “No” in column c0020 to indicate that the FMI is not a CEF, the system still requires completion of columns c0030 and c0040. We do not fully understand this requirement: if we have indicated that the FMI is not a CEF, we should not be expected to provide any CEF in column c0040, nor the CEF country in column c0030. Could you please advise on how we should proceed? As it stands, we would either need to enter an arbitrary CEF for FMIs that support a CBL but not a CEF, or the system should allow leaving columns c0030 and c0040 blank when c0020 = “No”.

0020-0040 Critical FMIs 0020 Critical FMI: Y/N ‘Yes’ if the FMI is critical ‘No’ if the FMI is not critical   Columns 0020 and 0050 are not mutually exclusive. 0030 Country Country in which the critical function is provided, as reported in Z 07.01  0040 Critical function ID Critical function(s) performed by the entity, the performance of which would be impeded or prevented by the disruption of access to the FMI service provider. ID of the critical functions as reported in Z07.01 :   Deposits Deposits from Households Deposits from Non-financial corporations  Deposits from Non-financial corporations SMEs Deposits from Non-financial corporations non-SMEs Deposits from General Governments Deposits from other sectors / counterparties (1) Deposits from other sectors / counterparties (2) Deposits from other sectors / counterparties (3)   Lending Lending to Households Lending to Households for house purchase Lending to Households for other than house purchase Lending to Non-financial corporations Lending to Non-financial corporations SMEs Lending to Non-financial corporations non-SMEs Lending to General Governments Lending to other sectors / counterparties (1) Lending to other sectors / counterparties (2) Lending to other sectors / counterparties (3)   Payment, Cash, Settlement, Clearing, Custody  Payment services to MFIs Payment services to non-MFIs Payment services to non-MFIs for Households Payment services to non-MFIs for Non-financial corporations Payment services to non-MFIs for Non-financial corporations SMEs Payment services to non-MFIs for Non-financial corporations non-SMEs Cash services Securities settlement services CCP clearing services Custody services Other services / activities / functions (1) on payments, cash, settlement, clearing and custody services Other services / activities / functions (2) on payments, cash, settlement, clearing and custody services Other services / activities / functions (3) on payments, cash, settlement, clearing and custody services   Capital Markets Derivatives held for trading  Derivatives held for trading in OTC Derivatives held for trading in non-OTC Secondary markets / trading Primary Markets / underwriting Other services / activities / functions (1) in capital markets Other services / activities / functions (2) in capital markets Other services / activities / functions (3) in capital markets   Wholesale Funding Borrowing Derivatives (assets) Lending Derivatives (liabilities) Other product types (1) in wholesale markets Other product types (2) in wholesale markets Other product types (3) in wholesale markets