EBA · 2026_7825 Rejected question

Templates Z09.02 - 'Country 0030 ' and 'Critical functions ID 0040' for Essential FMIs

Regulation
Directive 2014/59/EU (BRRD)
Article
11
Topic
BRRD Reporting
Submitted by
Credit institution
Submitted
2026-04-10

Question

Please confirm what should firms populate in Template 9.02 columns 'Country 0030 ' and 'Critical functions ID 0040' for non-critical FMIs as these columns cannot have null values.

Background

Per the Annex II instructions, column 0030 Country should reflect the “country in which the critical function is provided, as reported in Z 07.01,” and column 0040 Critical Functions ID should include the “ID of the critical function(s) performed by the entity whose performance would be impeded by disruption of access to the FMI, as reported in Z 07.01.” We interpret this to mean that both columns should remain blank for FMIs that are not critical (i.e., column 0020 = “No”). However, the taxonomy does not currently allow these fields to be left null.   See response from Nasdaq below.  According to the EBA XBRL Taxonomy, column 0030 is represented by the fixed dimension “LCF_GA8_1_WITHOUT_X0 – Location of critical function”, which has a predefined list of members specified by the regulator. As a result, this column cannot be left empty and must be populated with one of the values from the prescribed list. Also, under the EBA XBRL Taxonomy, column 0040 is represented by the fixed dimension “qCRH – Critical function (CF to LE) (new_TZ1)”, which has a predefined list of members defined by the regulator. Consequently, this column cannot be left empty and must contain one of the values from the corresponding list.
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Original source: European Banking Authority, Q&A ID 2026_7825

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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