EBA · 2026_7824 Final Q&A

Templates Z09.01 - Services provided to and received from FMI/Intermediary

Regulation
Directive 2014/59/EU (BRRD)
Article
11
Topic
BRRD Reporting
Submitted by
Credit institution
Submitted
2026-04-10
Answered
2026-10-09
Answer provided by
ESAs (EBA, ESMA, EIOPA)

Question

Could the EBA please confirm instruction interpretation for col 0220 and Col0210 of Template 09.01 (FMI Services - Providers and Users).

Background

Per our interpretation of Annex II instructions for col 0220 and Col0210 of Templates 09.01 (FMI Services - Providers and Users),  - Services provided by the reporting entity to the intermediary should be reported in column 0210 only where they are directly related to the FMI governing contractual relationship, for example services enabling or supporting settlement, clearing, liquidity provision, custody, cash settlement), or operational access to the FMI. - Services exchanged with the intermediary that are not part of the contractual relationship with the FMI (i.e. broader bilateral, commercial or intragroup services that are not part of governing contractual relationship with the FMI access or operation) should not be reported in template Z 09.01. Thus, reporting under template Z 09.01 should be limited to services that are relevant to the FMI governing contractual relationship. It should not be understood as a comprehensive inventory of all services exchanged with an intermediary, but rather as a targeted disclosure of those services that are in connection with the governing contract enabling access to, or the functioning of, a Financial Market Infrastructure.

Answer

Reporting under template Z 09.01 should be limited to services that are relevant to the contractual relationship governing access to, or the functioning of, the FMI, including services supporting direct or indirect access to the FMI. Generic commercial, operational or intragroup services exchanged with an intermediary that are unrelated to that FMI relationship should not be reported.

Original source: European Banking Authority, Q&A ID 2026_7824

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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