EBA · 2026_7926 Final Q&A

Template Z08.02: Reporting of applications owned and operated by affiliated service providers

Regulation
Directive 2014/59/EU (BRRD)
Article
11, para. 3
Topic
BRRD Reporting
Submitted by
Credit institution
Submitted
2026-07-01
Answered
2026-09-18

Question

Where a reporting entity receives services from an affiliated entity and relies on applications that are owned, managed and operated by that affiliated service provider, should those applications be reported in template Z08.02 by the receiving entity? Alternatively, should template Z08.02 be limited to operational assets that are owned, managed or directly controlled by the reporting entity, with dependencies on affiliate-owned applications being reflected through the relevant service provider and outsourcing/inter-affiliate reporting templates?

Background

Template Z08.02 requires the reporting of operational assets supporting critical functions and core business lines, including applications and information systems. In some banking groups, critical functions and core business lines are supported through intra-group service arrangements, whereby services are provided by another group entity. The applications supporting these services may be owned, managed, and operated by the service-providing group entity rather than by the reporting institution itself. It is unclear whether the intention of template Z08.02 is to capture: - operational assets owned, managed or controlled by the reporting entity (BofAE); or - all applications that support the reporting entity's critical functions and core business lines, including those owned and operated by affiliated service providers. Where applications are owned and operated by another group entity, the reporting institution's dependency is on the service received rather than on the underlying application itself. Reporting such applications in Z08.02 may therefore extend beyond operational assets that are directly managed or controlled by the reporting institution. Clarification is requested as to whether applications owned and operated by another group entity, but supporting services provided to the reporting institution, should be reported in template Z08.02.

Answer

According to Article 3(1) of the ITS, the information reported in template Z 08.02 covers all group entities. Since Z 08.02 is reported once at group level, it is not limited to operational assets owned, managed or directly controlled by the receiving entity. It should also include operational assets owned and operated by affiliated entities where those assets underpin services supporting the group's critical functions or core business lines. The assets should be reported once at group level and linked to the relevant service as required by the template. The information in column 0070 (legal/contract type) should be provided from the perspective of the entity to which the intra-group or intra-entity service provider belongs.

Original source: European Banking Authority, Q&A ID 2026_7926

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.

Similar Q&As

More Q&As on this topic

📋 Track EU financial regulation continuously

Forseti monitors EU financial regulation and delivers personalised alerts anchored to verified official sources.

14-day free trial. No credit card required.