Template Z09.01: EBA Taxonomy alignment with ITS Requirements -Annex II instructions

Does the EBA taxonomy need to be updated to allow column 0110 of template Z09.01 to be left null when col 0090 is 'Direct', consistent with the Annex II instructions?

For template Z09.01 – FMI Services (Providers and Users), the Annex II instructions state that column 0110 (“Criticality assessment by provider”) may remain empty when 'Direct' is reported in col 0090.   However, the technical taxonomy currently does not permit column 0110 to be left blank. This is confirmed per following response from Nasdaq: "From the perspective of the EBA XBRL Taxonomy and the relevant annotated templates for the RES module, column 0110 is defined as one of the key fields in report Z 09.01. Consequently, this column, together with the other applicable key columns, forms a unique key combination for each row of the template, thereby preventing the duplication of records. In addition, Annex II – Instructions on Resolution Planning Reporting published by the EBA also identifies this column as participating in the formation of a primary key, which must be unique for each row of the template. Therefore, from a technical standpoint, the presence of an empty value for the data driven dimension “qIFM – Intermediary facilitating access to a FMI” does not appear feasible. Such a scenario may prevent the correct generation of the relevant hypercube and, as a result, may not allow the creation of valid cell contexts for facts in the final XBRL output file."