EBA · 2026_7803 Rejected question

Z01.02 - Ownership structure: Investor code and type of code for multiple investments

Name: Z01.02 - Ownership structure: Investor code and type of code for multiple investments: EBA Q&A — EU Financial Regulatory Q&A
Creator: European Banking Authority
License: https://creativecommons.org/licenses/by/4.0/

Regulation: Directive 2014/59/EU (BRRD)
Article: DPM4.2 - Annex II Instructions
Topic: BRRD Reporting
Submitted by: Credit institution
Submitted: 2026-03-30

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Question

According to the Annotated Table Layout of DPM 4.2, c0020 - Code (Investor Code), is specified as a unique ID in the template. According to the instructions for filling out the template, the specification must maintain referential integrity with Z01.01, provided that the investor is a group company. Since there can exist multiple investments per investor, it is not possible to comply with these requirements completely. How shall c0020 and c0030 (Type of code) be reported in such cases ?

Background

Within the Commerzbank Group, there are numerous relationships originating from the same investor. Consequently, this issue gains increased significance in the context of year-end reporting.

No answer published yet.

Original source: European Banking Authority, Q&A ID 2026_7803

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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