SRB Requests to Industry 2027: Three-Year Cycle, Fixed RESOL Dates
On 7 October 2026 the Single Resolution Board (SRB) published its list of consultations and SRB requests to industry for 2027, about two months earlier than the 2026 list of 1 December 2025. Two changes land directly on resolution reporting teams. The quarterly sign-off form on MREL eligibility of reported liabilities is discontinued with immediate effect, and from 2027 a broad set of bank-specific deliverables moves from annual requests to a three-year submission cycle where no material resolvability concerns exist.
The regulatory returns underneath keep fixed 2027 deadlines: RESOL1 and RESOL2 under Commission Implementing Regulation (EU) 2025/2303, the quarterly MREL-TLAC report and the resolvability work programme all sit outside the new cycle. The SRB’s publication provides an overview of planned consultations, reporting requests and resolvability deliverables for 2027. Applicable legal reporting obligations and institution-specific requirements continue to depend on the governing instruments and instructions issued to each bank. Bank-specific requests come through the annual priority letter, and the SRB says each bank has already received a list adjusted to its situation.
Related reading: SRB Resolution Reporting: RESOL 1 and RESOL 2 Under the New ITS
SRB requests to industry with fixed 2027 dates
Table 2.1 of the list carries the annual requests and Expectations for Banks (EfB) deliverables for banks under the SRB’s remit earmarked for resolution. None of them sits inside the three-year cycle:
| Request | Scope in the list | Deadline |
|---|---|---|
| Resolvability work programme for 2027 | Resolution groups | 1 February 2027 |
| EBA MREL-TLAC report and SRB MREL quarterly monitoring | Resolution groups | 18 February, 19 May, 18 August and 18 November 2027 (Q4 2026 to Q3 2027 data) |
| RESOL1, organisation and liability data | All banking groups under the SRB’s remit | 31 March 2027 |
| RESOL2, critical functions, relevant services and FMIs | All banking groups under the SRB’s remit | 30 April 2027 |
| Funding plan | Resolution groups | 31 December 2027 |
| 2028 resolvability self-assessment report | Resolution groups | 31 January 2028 |
The self-assessment report runs on its own two-year rhythm: the 2026 report was due on 2 February 2026, and the next one reflects the position at 31 December 2027. Resolvability testing outcome reports carry no list date; they follow the deadlines agreed in each bank’s Multi-Annual Testing Programme, which the list says normally produces several reports per institution per year.
The funding plan is the row to reconcile against last year’s planning. The 2026 list did not itemise it; the 2027 list cites the SRB’s operational guidance on resolvability self-assessment as the basis for a funding plan submitted at least annually, showing how the bank will achieve or maintain MREL compliance.
Where the three-year submission cycle applies
The cycle attaches to Table 2.2, the SRB’s list of additional potential requests for 2027 based on the outcome of the resolvability assessment. Its potential requests cover MREL evidence, bail-in execution, liquidity, valuation, separability, communication and other resolvability capabilities.
The trigger sits in a footnote. Where the outcome of the resolvability assessment, as reflected in the heatmap, shows no material issues or only limited areas still to be enhanced, the relevant Table 2.2 deliverable is subject to a three-year cycle and requested only once every three years, as an update or a reconfirmation. The Internal Resolution Team (IRT) identifies the applicable deliverables and their submission timetable through the bank’s annual priority letter. Where a Table 2.2 deliverable is requested for the 2027 cycle, the letter sets the timeline, with a default deadline of 31 December 2027 unless it states otherwise. One row brings its own date: banks in scope are expected to submit an updated communication plan by April 2028, the horizon covered in our note on the SRB resolution communication plan.
The SRB’s numbers come with conditions attached. Over the medium term, and assuming legal stability, banks with consistently satisfactory resolvability performance can expect requests tied to these deliverables to fall by up to one-third a year compared with the current situation. Where a deliverable remains up to date and fit for purpose, the bank can confirm that when due instead of resubmitting. The cycle does not apply where material resolvability concerns exist.
One scope label is easy to misread. Most Table 2.2 rows say “Limited” or “Resolution Groups”, yet the two liquidity rows, covering Key Liquidity Entity and Key Liquidity Driver identification with the liquidity estimation methodology, and the collateral note with the SRB collateral template, say “All”, which the list defines as all banking groups under the SRB’s remit. This reads as the SRB keeping the option to ask any bank for these items under the revised guidance explained in our guide to liquidity and funding in resolution. Whether a bank receives them turns on its priority letter.
The SRB’s 2026 Table 2.2 included separate potential requests for digital operational resilience testing results and FMI contingency plans. Institutions should assess their 2027 priority letters for any continuing, revised or additional requests relating to these capabilities. The SRB’s press release describes the 2027 table as listing all elements that could potentially be requested from banks in 2027.
The MREL sign-off form ends, the quarterly MREL data keeps flowing
In the 2026 list, the sign-off form on MREL eligibility of reported liabilities sat in Table 2.1 for resolution groups, submitted with each quarterly MREL report to give the SRB additional assurance on liabilities reported as eligible. On a plain reading of “immediate effect”, the 18 November 2026 submission of Q3 2026 data is the first without it.
The EBA MREL-TLAC report under Commission Implementing Regulation (EU) 2021/763 stays, and so does the SRB MREL quarterly monitoring template, which collects issuances and forecasts outside that regulation and feeds the dashboards discussed in our review of the SRB MREL Dashboard for H2 2025.
The eligibility evidence has changed tables. The self-assessment template on eligible liabilities, in Table 2.1 in 2026 with a deadline of eight weeks after the IRT’s request, is now a Table 2.2 potential request. It still covers specific issuances the SRB identifies periodically, tested against the CRR and Commission Delegated Regulation (EU) No 241/2014 as amended by Delegated Regulation (EU) 2023/827, with paragraph 110 of the SRB MREL policy as reference. The route changes; the list leaves the eligibility criteria themselves untouched. Our guide to MREL reporting requirements covers the template layer.
Footnote 1 of the list excludes additional requests made on behalf of national resolution authorities (NRAs), so the SRB list does not by itself withdraw an NRA instruction that still refers to the sign-off form. Table 1 schedules an MREL policy update implementing the crisis management and deposit insurance (CMDI) review for Q2 2027, open to all stakeholders, alongside a Q2 2027 workshop on updating the 2022 bail-in playbook guidance.
RESOL1 and RESOL2 in their second year
The 2027 collection is the second under Commission Implementing Regulation (EU) 2025/2303 of 14 November 2025, published in the Official Journal on 10 December 2025. It repealed Implementing Regulation (EU) 2018/1624, and its templates replaced the SRB’s Liability Data Report, Critical Functions Report and Financial Market Infrastructure Report from the 2026 cycle. The SRB’s 2026 reporting page used the same 31 March and 30 April dates, collects RESOL1 and RESOL2 from NRAs exclusively in XBRL-csv, and strongly encourages banks to run its Level 3 data quality checks (version 2.1, last updated 1 April 2026) before submitting.
The link to the three-year cycle runs through the resolvability assessment. On that page the SRB says data quality and timely availability are key items in the assessment, and that it can treat failure to comply with information requirements as an impediment to resolvability, potentially a significant one. The same assessment’s outcome informs whether Table 2.2 deliverables move to the three-year cycle. Read together, the two tie RESOL submission quality to how much bank-specific work returns each year; the 2027 list does not draw that connection itself.
The operational continuity row shows the overlap from the other side: the list limits additional information on operational continuity in resolution (OCIR) to what the EBA resolution reporting standard templates do not already cover.
SRF and administrative contribution windows in the same list
Table 3 cites Articles 70(1) and 71 of Regulation (EU) No 806/2014 (SRMR) and Article 14 of Commission Delegated Regulation (EU) 2015/63, with Single Resolution Fund (SRF) data windows from 1 November 2026 to 1 February 2027 and to 15 January 2027. Article 14(4) of Commission Delegated Regulation (EU) 2015/63 provides for submission of the required information by 31 January, or the following business day where applicable. Institutions must follow their NRA’s communicated filing timetable, while arrangements for restated forms should be checked against the SRB’s 2027 contribution-period instructions. The Luxembourg timeline is in our CSSF-CODERES 26/22 note.
Whether a levy follows is still open. A target level verification in February 2027 tests the Fund against the Article 69(1) SRMR threshold of at least 1% of covered deposits. A consultation, in principle in the first half of March 2027, covers preliminary contribution amounts only if contributions are collected in 2027, plus restatement settlements where applicable. Administrative contribution consultations run in January and February 2027 for advance instalments (SRB entities only) and in June and July 2027 for annual contributions.
Frequently Asked Questions
Our IRT has put a Table 2.2 deliverable on the three-year cycle. Can the SRB still ask for it earlier?
The list is silent on the years between updates. The SRB adds that requests to individual banks will be informed by resolvability assessments, testing outcomes, on-site inspections and its evolving priorities. My working assumption is that a three-year date can move forward if one of those inputs changes; neither document says it is fixed.
We are a subsidiary reporting on an individual basis. Does a “Resolution Groups” scope reach us?
Possibly. Footnote 2 says the scope definitions might cover subsidiaries reporting on an individual basis, and that “resolution groups” will also capture some subsidiaries in line with specific IRT instructions or accompanying reports. The IRT instruction decides.
Does the Additional Liability Report keep its March window?
The 2027 list gives it no window. In 2026 it ran from 1 to 31 March; in 2027 it appears in Table 2.2 as a potential bank-specific request with “Limited” scope, primarily for groups following a multiple point-of-entry resolution strategy. Although the SRB describes the report as an annual data request, its inclusion in Table 2.2 means that the applicable submission or reconfirmation frequency must be read together with the three-year-cycle arrangements and the bank’s priority letter. Absent another date in the priority letter, the Table 2.2 default of 31 December 2027 is the only date the list provides.
Related Articles
- SRB Resolution Reporting: RESOL 1 and RESOL 2 Under the New ITS: scope, deadlines, format and validation for the RESOL templates.
- MREL Reporting Requirements: the MREL and TLAC templates and the quarterly remittance cycle.
- SRB MREL Dashboard H2 2025: Year-End Resolution Benchmarks: what the SRB publishes from quarterly MREL data.
- CSSF-CODERES 26/22: SRF Data Reporting Due 15 January 2027: the Luxembourg route for the 2027 SRF data reporting form.
Sources and References
- SRB press release on the 2027 list (7 October 2026): srb.europa.eu
- SRB, Upcoming Consultations and Requests to the Industry for 2027 (PDF): srb.europa.eu
- SRB, Upcoming consultations and requests to the industry for 2026 (PDF, 1 December 2025): srb.europa.eu
- SRB, 2026 Resolution Reporting: srb.europa.eu
- SRB, Expectations for Banks: srb.europa.eu
- Commission Implementing Regulation (EU) 2025/2303: EUR-Lex
- Commission Implementing Regulation (EU) 2021/763: EUR-Lex
- Commission Delegated Regulation (EU) No 241/2014: EUR-Lex
- Commission Delegated Regulation (EU) 2023/827: EUR-Lex
- Regulation (EU) No 575/2013 (CRR): EUR-Lex
- Commission Implementing Regulation (EU) 2018/1624 (repealed by Implementing Regulation (EU) 2025/2303): EUR-Lex
- Regulation (EU) No 806/2014 (SRMR): EUR-Lex
- Commission Delegated Regulation (EU) 2015/63: EUR-Lex
- SRB kick-off letter for the 2027 contribution period (10 September 2026): srb.europa.eu
Rebuilding the 2027 resolution calendar from the priority letter
Each bank’s 2027 priority letter identifies its scheduled bank-specific deliverables. However, the published list does not prevent further information requests: the SRB retains discretion to seek additional information where necessary, and separate instructions from national resolution authorities may also apply. For a Table 2.2 item that applies to the bank, the letter either sets a 2027 deadline or names the year in which the next update is required, and that entry belongs in the 2027 plan. For resolution planning, the first listed date is 1 February 2027 for the resolvability work programme, followed by the Q4 2026 MREL-TLAC report on 18 February and RESOL1 on 31 March.
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.