SRB Business Reorganisation Plan Analysis Report: No New Requirements

On 30 July 2026 the Single Resolution Board published a renewed Operational Guidance on the Business Reorganisation Plan Analysis Report, together with a complementary quantitative template and a feedback statement closing the public consultation that ran from 3 February to 30 March 2026. The SRB is explicit on one point that shapes how reporting and resolution teams should read the package: there are no new requirements. The guidance, marked Version 1.1, July 2026, compiles and clarifies expectations that already sit in the Bank Recovery and Resolution Directive, the Single Resolution Mechanism Regulation and the SRB’s own Expectations for Banks.

That framing matters because the document it supports, the business reorganisation plan analysis report, is easy to mistake for a new deliverable. It is a capability that banks under the SRB’s remit are expected to build and evidence in peacetime where the open bank bail-in tool is envisaged as part of their resolution strategy, including where it is the preferred or a variant resolution tool, so that a full business reorganisation plan can be produced within the one-month statutory period after bail-in. The renewed guidance gives those banks a single reference for what that evidence should contain and a non-mandatory template to structure it.

Related reading: our guide to the SRB’s operational guidance on liquidity and funding in resolution, which sits alongside this report in the SRB’s resolvability-testing toolkit.

What the SRB actually released on 30 July 2026

The package has three parts. The Operational Guidance on the Business Reorganisation Plan Analysis Report (a 2.04 MB PDF, publishing date 29 July 2026) is the narrative reference. Annex V, the Business Reorganisation Plan Analysis Report quantitative template (a 984 KB XLSX, publishing date 16 July 2026), is the optional structured workbook. The feedback statement (a 1.77 MB PDF, publishing date 29 July 2026) records how the SRB responded to consultation comments. SRB Chair Dominique Laboureix positioned the guidance as part of the Board’s broader work on resolvability self-assessment and resolvability testing.

For anyone building a resolution-readiness calendar, the operative dates are worth pinning:

• Public consultation: 3 February to 30 March 2026.
• Quantitative template published: 16 July 2026.
• Operational Guidance (Version 1.1) and feedback statement published: 29 July 2026.
• Press release and public launch: 30 July 2026.

Those dates describe the guidance publication cycle and do not themselves create a new universal filing deadline. BRP AR delivery remains bank-specific within the resolution planning cycle: the SRB’s 2026 requests document sets applicable BRP AR deadlines; banks are informed individually via their Internal Resolution Team’s priority letter, and IRT-specific earlier dates may apply. Timelines for subsequent deliverables are discussed individually with the Internal Resolution Team for each resolution planning cycle.

Capability now, plan later: two documents with one name

The most common misreading of this framework conflates two different documents that share most of a name. The business reorganisation plan, or BRP, is the crisis-time document. Article 52 of the Bank Recovery and Resolution Directive requires that, within one month after the bail-in tool is applied to recapitalise an institution, the management body or an appointed person draws up and submits a business reorganisation plan to the resolution authority. The business reorganisation plan analysis report, or BRP AR, is the peacetime document. It is the evidence a bank assembles now to show it could produce that crisis-time plan on the required timeline and to the required standard.

The SRB’s Expectations for Banks put this in Principle 7.3: institutions are expected to prepare ex ante preliminary assessments of the key elements of a business reorganisation plan to ensure resolution readiness. The analysis report is how a bank demonstrates that its governance, data and analytical capabilities are genuinely in place, with evidence behind each claim. In the guidance’s own words, an institution is expected to evidence its capabilities relating to the preparation of a potential plan, and to provide reasonable prospects of financial soundness and post-bail-in long-term viability.

Reading the two as one deliverable leads teams to either over-build (drafting a speculative full reorganisation plan years ahead of any crisis) or under-build (treating the exercise as a narrative note rather than a tested capability). The report sits between those two errors: a structured demonstration of readiness, kept current, that stops short of committing to a fixed post-resolution blueprint.

Where the legal obligation actually sits

The guidance is a reference layer over obligations that live elsewhere in EU law, and it says so plainly: it is not legally binding and does not substitute or amend the requirements in EU and national law. The underlying duty runs through several instruments. Article 27(16) of the Single Resolution Mechanism Regulation (Regulation (EU) No 806/2014) and Article 52 of the Bank Recovery and Resolution Directive (Directive 2014/59/EU) set the requirement for a business reorganisation plan after bail-in. Commission Delegated Regulation (EU) 2016/1400 is the regulatory technical standard specifying the minimum elements of that plan and the minimum contents of the reports on progress in implementing it. Commission Delegated Regulation (EU) 2016/1075 covers the wider resolution-planning technical standards. On the guidelines side, EBA/GL/2015/21 specifies the minimum criteria that a business reorganisation plan must fulfil for approval. The SRB guidance also draws on the EBA Guidelines on improving resolvability and EBA/GL/2023/06 for related resolvability and recovery-planning concepts, but those instruments do not replace or extend the BRP-specific approval criteria.

The timeline embedded in Article 52 BRRD is the reason the analysis report has to exist well in advance of any crisis. The management body must submit the plan within one month of the bail-in application. Article 52(3) allows the resolution authority to extend that window to a maximum of two months in exceptional circumstances. Where the business reorganisation plan is required to be notified within the Union State aid framework, the extension is to a maximum of two months from the application of the bail-in tool or until the Union State aid deadline, whichever occurs earlier. Under the SRMR procedure, the national resolution authority forwards the plan to the Board and provides its own assessment within two weeks; the Board assesses within one month whether the plan would restore long-term viability; if amendments are required, the management body has two weeks to resubmit, and the Board gives its final view within one week. Once a plan is approved, Article 52(10) BRRD requires progress reports on implementation at least every six months.

Producing a credible reorganisation plan within the one-month post-bail-in window, in parallel with everything else running across a resolution weekend, demands analytical groundwork completed well in advance. That is the practical case for the analysis report, and it is why the SRB frames readiness rather than a new form.

Who is expected to evidence a business reorganisation plan analysis report

The expectation is narrower than the whole Banking Union. It applies to institutions under the SRB’s remit where the open bank bail-in tool is envisaged as part of the resolution strategy, whether as the preferred tool or a variant. Banks with insolvency or transfer-only strategies face different resolvability expectations, but a bank should not be treated as out of scope merely because its preferred strategy is a transfer if open bank bail-in is retained as a variant.

That distinction is the one to get right before scoping any internal project. The open bank bail-in tool can only be applied where there are reasonable prospects of restoring the institution to financial soundness and long-term viability, a prerequisite set in Article 27(2) SRMR and Article 43(3) BRRD. The analysis report is the ex ante evidence base for that prospect. A bank whose plan never envisages continuation after bail-in is answering a different resolvability question and should not be reverse-engineering a reorganisation report it would never file.

The SRB also builds in proportionality on timing and maintenance. Work on the analysis report is iterative: once a bank’s Internal Resolution Team considers the objectives met, the bank is expected to update the report only when a material change occurs, for example a change in governance or internal process that affects how the plan would be produced, a change in the elements underpinning the demonstration of long-term viability, or an explicit request from the Internal Resolution Team. It is not designed as an annual rewrite. The loss-absorbing capacity that makes the whole bail-in path feasible is a separate reporting stream; see our explainer on MREL reporting requirements for how banks evidence that capacity.

The six elements the SRB expects the report to describe

The guidance sets a minimum content standard. A business reorganisation plan analysis report is expected to describe, at a minimum, six elements:

• the governance and operational arrangements to produce and implement a business reorganisation plan on a timely basis;
• the institution’s strategic views and preliminary analysis of its target business model, geographical footprint and internal organisation after an open bank bail-in;
• the identification of business reorganisation measures, drawing on both recovery options and complementary reorganisation measures, that would enhance post-bail-in long-term viability or help reach the Core Bank;
• an initial evaluation of those measures, with the timelines needed to prepare and execute them and a quantification of their effect on restoring financial soundness and viability;
• a demonstration that long-term viability can reasonably be met at the end of the reorganisation period, supported by financial projections;
• the quantification of the maximum reorganisation capacity.

Two of these carry most of the analytical weight. The financial projections are expected to run over a five-year horizon. The feedback statement is precise about the boundary between two things reviewers often collapse into one: the post-bail-in snapshot is a baseline assessment of the institution’s immediate financial status just after bail-in, notably its compliance with capital requirements, while the five-year projections are what actually demonstrate sustainability over time and the achievement of the Core Bank at the end of the projection period. A snapshot alone does not answer the viability question, and a bank that submits only a static picture of its day-one balance sheet has evidenced the easier half of the exercise.

Identifying the Core Bank and sizing the reorganisation

The Core Bank is the viable entity the guidance asks banks to define as the endpoint of reorganisation. Core Bank identification runs through the continuation of critical functions in the short, medium and long term, and the treatment of core and non-core business lines after an open bank bail-in. The point of the exercise is to show what the institution looks like once loss-making or non-viable activity has been wound down or divested and the remaining franchise can stand on its own.

The bridge between the measures and the Core Bank is the maximum reorganisation capacity, or MRC. It quantifies the maximum effect of the reorganisation measures, giving a view of how far a bank could restore post-bail-in viability. Annex II gives an indicative list of complementary measures, including staff and branch-network reductions, sale-and-leaseback of a head office, and reductions in IT and consultancy costs. Separately, the guidance expects the annual effect of each measure to be estimated, at a minimum, for return on equity, cost-to-income ratio, CET1, total capital ratio, risk-weighted assets and LCR; additional metrics may be provided. The MRC itself is defined by the combined effect on return on equity and cost-to-income ratio at the end of the projection period.

The feedback statement clears up a question several respondents raised: whether a sensitivity analysis is mandatory. It is not automatically. Where a sensitivity analysis is performed, it adds a buffer to the optimal combination of measures, accounting for uncertainty and more distressed scenarios, and the combination gives the true maximum reorganisation capacity. Where it would be immaterial, for instance a bank that has recently completed a restructuring so that further branch-network cuts would have very limited impact, the guidance accepts that a bank can simply state that the sensitivity analysis is not relevant, in which case the capacity figure is limited to the optimal combination of measures and no buffer is identified. That carve-out is worth flagging early to an Internal Resolution Team, because assuming a mandatory buffer where none is meaningful wastes analytical effort.

How the report connects to recovery planning without duplicating it

Respondents saw an obvious overlap between the strategic analysis in recovery planning and Core Bank identification, and asked whether the two could be aligned. The SRB confirms that the analysis report can leverage insights from recovery planning, and that a bank may use its latest recovery plan even where that plan is due to be updated shortly after the report is submitted. Banks are also invited to use the analysis report to support their recovery-planning work, given the natural link between the two.

The two documents are not interchangeable, and this is the misconception most likely to survive into a project plan. Recovery planning focuses on pre-resolution stabilisation, keeping the bank alive as a going concern. The analysis report has to prove something different: that the institution can achieve sustainable profitability after resolution measures have been applied, which is a forward-looking viability assessment specific to the post-bail-in world. A bank that copies its recovery plan’s strategic section into the report and stops there has answered the wrong question. The recovery options feed the reorganisation measures; they are one input among several, and they do not replace the viability demonstration. For the supervisory read on recovery-plan quality, the EBA’s recovery plan dry-run findings are a useful reference point on where recovery analysis tends to fall short.

The quantitative template and what stays voluntary

The template is the part of the package most likely to be misread as an obligation. It is non-mandatory. The SRB describes it as practical support to help banks structure the quantitative side of the report, and the guidance itself reserves the right to deviate from the actions and expectations it describes, case by case, in line with the applicable legal framework. Using the workbook is optional, and a bank that presents the same quantitative evidence in its own format is not out of line with the guidance.

What the template does offer is a shared reference for the numbers, which is the whole reason industry asked for the publication in the first place: a publicly available, standardised reference to harmonise expectations and improve consistency across banks and across Internal Resolution Teams. For a Banking Union bank building this capability, the practical question is how to evidence a business reorganisation plan analysis report, and the template lowers the cost of getting the quantitative structure right the first time. This publication also fits the SRB’s wider simplification and crisis-preparedness agenda, which the Board has been signalling through its recent messaging on resolution-planning simplification and the broader reform of the EU crisis-management framework covered in our note on the CMDI package.

Frequently Asked Questions

Does the renewed guidance create a new reporting obligation or a new filing deadline?

The renewed guidance creates no new universal obligation or filing deadline. However, BRP AR submissions can have bank-specific resolution-planning deadlines set through the Internal Resolution Team’s priority letter. For the 2026 cycle, applicable deadlines are set out in the SRB’s 2026 requests document and may be brought forward by the Internal Resolution Team’s priority letter.

When does the one-month clock in Article 52 BRRD actually start?

It starts when the bail-in tool is applied to recapitalise the institution, not when resolution is first triggered. The management body then has one month to submit the full business reorganisation plan, extendable to a maximum of two months in exceptional circumstances under Article 52(3) BRRD; in State aid notification cases, to a maximum of two months or the Union State aid deadline, whichever occurs earlier.

Our resolution strategy is a transfer, not open bank bail-in. Do we still need an analysis report?

The report addresses the open bank bail-in path specifically, where the bank is recapitalised and continues to operate. A strategy built on sale of business or a bridge institution answers a different resolvability question. However, if open bank bail-in is retained as a variant tool within your strategy, the expectation can still apply. Confirm your preferred and variant strategies with your Internal Resolution Team before scoping the work, and before assuming the report does not apply.

Can we reuse our recovery plan to satisfy the report?

Partly. You may leverage recovery-planning analysis and use your latest recovery plan as an input, but the report must prove post-resolution viability, a forward-looking assessment that recovery planning, which targets pre-resolution stabilisation, does not perform. Recovery options feed the reorganisation measures; they do not discharge the viability demonstration.

Is a sensitivity analysis mandatory when calculating the maximum reorganisation capacity?

Not automatically. Where performed, it adds a buffer for uncertainty and more distressed scenarios and completes the maximum reorganisation capacity. Where it would be immaterial, for example after a recent restructuring, the SRB accepts a statement that the sensitivity analysis is not relevant, and the capacity figure is limited to the optimal combination of measures with no buffer.

How often do we have to refresh the analysis report once the SRB is satisfied?

Once the Internal Resolution Team considers the objectives met, updates are expected only on a material change, such as a governance or internal-process change affecting how the plan would be produced, a change in the elements underpinning long-term viability, or an explicit Internal Resolution Team request. Separately, once a real plan is approved after a bail-in, Article 52(10) BRRD requires progress reports at least every six months.

Do we have to use the SRB’s quantitative template?

No. It is non-mandatory practical support. A bank can present equivalent quantitative evidence in its own format; the template exists to standardise the structure and reduce build effort, not to serve as a compliance gate.

Related Articles

• SRB Operational Guidance on Liquidity and Funding in Resolution: the companion capability on liquidity estimation and key liquidity entities in resolution.
• MREL Reporting Requirements: how banks evidence the loss-absorbing capacity that makes an open bank bail-in feasible.
• EBA Recovery Plan Dry Run Report: supervisory findings on recovery-plan quality that feed into reorganisation analysis.
• CMDI Official Journal Publication: the reform reshaping the EU crisis-management and deposit-insurance framework.
• SRB 2025 Annual Report on Crisis Readiness: where the analysis report sits in the Board’s resolvability programme.
• SRB Response on Banking Competitiveness: the simplification agenda behind the consolidated guidance.

Key Takeaways

• The renewed guidance (Version 1.1, published 30 July 2026) adds no new requirements; it consolidates existing Article 52 BRRD and SRMR expectations plus a non-mandatory template.
• Distinguish the peacetime analysis report (evidence of capability) from the crisis-time business reorganisation plan (due within one month of bail-in under Article 52(1) BRRD).
• Scope the work to your resolution strategy: the report applies where open bank bail-in is envisaged as part of the strategy, whether as the preferred tool or a variant, subject to confirmation with your Internal Resolution Team.
• Build all six minimum elements; the five-year projections and the maximum reorganisation capacity carry the viability case, and a day-one post-bail-in snapshot alone is not enough.
• Treat a sensitivity-analysis buffer as conditional: state it as not relevant where a recent restructuring makes further measures immaterial.
• Use recovery-planning analysis as an input, not a substitute; the report must prove post-resolution viability, which recovery planning does not.
• Refresh the report only on material change once the Internal Resolution Team is satisfied; the six-month cadence under Article 52(10) BRRD applies to progress reports on a real plan.

Sources and References

• Single Resolution Board, press release, “SRB publishes a renewed Operational Guidance on Business Reorganisation Plan Analysis Reports” (30 July 2026): srb.europa.eu
• Single Resolution Board, “Operational Guidance on the Business Reorganisation Plan Analysis Report”, Version 1.1, July 2026 (PDF): srb.europa.eu
• Single Resolution Board, “Feedback Statement on the public consultation on the Operational Guidance on the Business Reorganisation Plan Analysis Report” (July 2026, PDF): srb.europa.eu
• Single Resolution Board, “List of consultations and requests to industry 2026” (published 01/12/2025): srb.europa.eu
• Directive 2014/59/EU (Bank Recovery and Resolution Directive), Article 52 (business reorganisation plan): eur-lex.europa.eu
• Regulation (EU) No 806/2014 (Single Resolution Mechanism Regulation), Article 27 (bail-in tool and business reorganisation plan procedure): eur-lex.europa.eu
• Commission Delegated Regulation (EU) 2016/1400 of 10 May 2016 (RTS on minimum elements of a business reorganisation plan and minimum contents of progress reports): eur-lex.europa.eu
• EBA Guidelines on the minimum criteria to be fulfilled by a business reorganisation plan (EBA/GL/2015/21): eba.europa.eu

What to put in front of your Internal Resolution Team next

The renewed guidance leaves what your bank owes exactly where it was and sharpens how clearly the SRB has written it down, while handing you a template for the numbers. The near-term action is narrow. Confirm with your Internal Resolution Team whether the open bank bail-in tool is in your resolution strategy, whether as the preferred tool or a variant, and if it is, map your existing recovery-planning analysis, financial-projection engine and Core Bank definition against the six minimum elements to find the gaps. The one that most often opens up is the five-year post-bail-in viability projection, and closing it is the work the SRB expects to see evidenced before the next resolution planning cycle turns.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.