MREL Reporting Requirements – Templates, Frequency, and What Your Resolution Authority Expects

ByOfficer

Last updated: March 2026

Your resolution authority has set your MREL requirement. You know the number. What you may not know is how to prove, every quarter, that you meet it. MREL reporting is not a single template and a single submission. It is a set of interlocking templates covering key metrics, creditor ranking, funding structure, maturity profiles, and instrument-level detail. Getting the MREL decision is the beginning. Demonstrating compliance through accurate, timely reporting is the ongoing obligation, and it is where teams run into trouble.

The reporting framework is anchored in Implementing Regulation (EU) 2021/763 (the ITS on disclosure and reporting of MREL and TLAC). The templates were significantly revised to reflect CRR2/BRRD2 (the 2019 Banking Package) and subsequently amended by CIR (EU) 2024/1618 to incorporate the daisy chain framework (Regulation (EU) 2022/2036) and prior permission deduction requirements. The framework now covers the dual expression of MREL (as a percentage of TREA and of the total exposure measure), subordination requirements, the distinction between resolution entities and non-resolution entities, and the deduction of intermediate entity holdings of internal MREL resources.

This article covers the reporting templates, what each one requires, the reporting frequency and deadlines, the MREL ratio calculation, the internal vs external MREL distinction, and the practical challenges that surface in Luxembourg institutions.

Related reading: MREL Prior Permission for Own Funds Reduction

The Legal Basis

MREL reporting obligations stem from two BRRD articles:

  • Article 45i requires institutions to report to their resolution authority and competent authority on the amounts and composition of own funds and eligible liabilities, on both an individual and consolidated basis, as well as changes to those amounts.
  • Article 45j requires resolution authorities, in coordination with competent authorities, to inform the EBA of the MREL decisions they have taken. The EBA uses this information for its MREL dashboard and convergence assessments.

The reporting templates for institutions (Article 45i) are in ITS 2021/763 (Annex I). The reporting templates for resolution authorities (Article 45j) are in a separate ITS on reporting of MREL decisions (ITS 2021/622, as amended). This article focuses primarily on the institution-facing reporting under Article 45i, which is what your finance and regulatory reporting teams are responsible for.

The Template Set

The MREL/TLAC reporting framework under ITS 2021/763 consists of the following templates. Not all templates apply to all institutions. The scope depends on whether the entity is a resolution entity (reporting external MREL) or a non-resolution entity (reporting internal MREL), and whether it is a G-SII subject to TLAC.

M 01.00 – Key Metrics (KM2)

This is the headline template. It reports the MREL and TLAC ratios expressed as a percentage of TREA (total risk exposure amount) and TEM (total exposure measure). It includes the numerator (own funds and eligible liabilities), the denominator (TREA and TEM), and the subordinated component.

Key fields: total own funds and eligible liabilities (row 0200), of which subordinated (row 0210), TREA (row 0100), TEM (row 0110), MREL as a percentage of TREA (row 0300), MREL as a percentage of TEM (row 0320). The template also captures whether the 5% subordination exemption under Article 72b(4) CRR applies, and the aggregate amount of permitted non-subordinated eligible liabilities under the 3.5% discretion in Article 72b(3) CRR.

In practice, M 01.00 is the template your management board will see in summary reports. The MREL ratio as a percentage of TREA and TEM are the numbers that determine whether you are in compliance with the requirement set by your resolution authority.

M 02.00 – Creditor Ranking (LIAB)

This template maps the institution’s liability structure by creditor ranking. It shows how liabilities are distributed across the insolvency hierarchy, from CET1 at the top through AT1, Tier 2, senior non-preferred, senior preferred, and excluded liabilities. The purpose is to give the resolution authority a clear picture of which liabilities would absorb losses and in what order under a bail-in scenario.

M 02.00 is one of the templates that creates the most work because it requires granular classification of the entire liability stack. Each liability must be allocated to its correct ranking position. Misclassification (placing a senior unsecured liability in the wrong ranking bucket) distorts the loss absorption analysis and will be flagged by the resolution authority.

M 04.00 – Funding Structure of Eligible Liabilities (LIAB-MREL)

This template breaks down eligible liabilities by type and maturity. It distinguishes between different classes of eligible liabilities (senior non-preferred bonds, senior preferred bonds, deposits above EUR 100,000, and other eligible liabilities) and reports their residual maturity in bands.

The maturity breakdown is critical for the resolution authority’s assessment of rollover risk. A high concentration of eligible liabilities maturing within one year signals that the institution could fall below its MREL requirement if market conditions prevent refinancing. The resolution authority monitors this template closely for cliff-risk concentrations.

For resolution entities, eligible liabilities as defined in Article 2(1)(71a) BRRD are reported. For non-resolution entities reporting internal MREL, eligible liabilities under Article 45f(2)(a) BRRD are reported. The distinction matters because the eligibility criteria differ.

M 05.00 – Instruments Governed by Third Country Law and M 07.00 – Third Country Law Instruments Detail (MTCI)

M 05.00 provides an overview of instruments governed by third country law that count toward MREL. M 07.00 provides a contract-by-contract breakdown of those instruments, including the issuing entity, contract identifier, governing law jurisdiction, type of own funds or eligible liabilities, outstanding amount, and maturity date.

These templates exist because instruments governed by third country law may not be automatically subject to the bail-in tool under BRRD. Article 55 BRRD requires a contractual recognition clause in instruments governed by third country law to ensure they can be written down or converted. The resolution authority needs to know which instruments are governed by which law and whether they include the Article 55 clause.

In Luxembourg, many institutions issue instruments under English law or New York law. If your institution has such instruments counting toward MREL, these templates are mandatory. The contract-by-contract detail in M 07.00 is granular: every instrument gets its own row with a unique combination of issuing entity code, contract identifier, and type classification.

M 06.00 – Internal MREL (ILAC)

This template applies to entities within a resolution group that are not themselves the resolution entity. These entities must meet an internal MREL requirement, which is typically met by issuing eligible liabilities to the resolution entity (upstream within the group). M 06.00 captures the internal MREL requirement, the available internal MREL resources, and the composition of those resources.

For groups with a single point of entry (SPE) resolution strategy, the resolution entity issues external MREL to the market, and subsidiaries issue internal MREL to the resolution entity. The internal MREL ensures that loss-absorbing capacity is prepositioned within the group so that individual subsidiaries can be recapitalized without triggering a full group resolution.

M 03.00 – MREL and TLAC Requirements, Ratios, and Additional Information (MREQ)

M 03.00 reports the MREL and TLAC requirements set by the resolution authority, the corresponding ratios, and additional information on how the requirement is met. It captures the requirement expressed as a percentage of TREA and TEM, the subordination component of the requirement, and information on any intermediate targets or transitional arrangements. The template was amended by Commission Implementing Regulation (EU) 2024/1618, which updated ITS 2021/763 to reflect changes in the daisy chain framework and prior permission deductions.

M 03.00 complements M 01.00: while M 01.00 reports the available resources (what you have), M 03.00 reports the requirement itself (what you need). The two templates together show whether the institution meets, exceeds, or falls short of its MREL. Your resolution authority will compare the ratios in M 01.00 against the requirements in M 03.00 as the primary compliance check.

Reporting Frequency and Deadlines

MREL/TLAC reporting under ITS 2021/763 follows the same quarterly frequency as COREP. Institutions report on reference dates of 31 March, 30 June, 30 September, and 31 December. The ITS specifies fixed remittance dates approximately 49 days after each reference date: 19 May (for Q1), 18 August (for Q2), 18 November (for Q3), and 18 February (for Q4).

For Luxembourg institutions, the MREL templates are submitted to the CSSF as part of the regular COREP reporting package. The CSSF transmits the data to the SRB (for Banking Union institutions under the SRM) and to the EBA. The submission is through the same reporting infrastructure used for COREP and FINREP: XBRL format through the CSSF’s reporting portal.

MREL decisions (the resolution authority side, under Article 45j) are reported separately. Resolution authorities currently inform the EBA of the MREL applicable at 1 May of each year by 31 May. The EBA uses this data for its MREL dashboard, which tracks the state of resolution planning and MREL compliance across the EU.

Note: the amended ITS on reporting of MREL decisions (amendments to ITS 2021/622) is moving toward semi-annual reporting by resolution authorities, with an expanded template scope. This will give the EBA more timely and granular data on MREL decisions, including mid-year updates. Institutions should expect their resolution authorities to request updated information more frequently to feed this enhanced reporting cycle.

The MREL Ratio Calculation

The MREL ratio is expressed two ways:

As a percentage of TREA (total risk exposure amount):

[latex]\text{MREL (TREA)} = \frac{\text{Own Funds} + \text{Eligible Liabilities}}{\text{TREA}} \times 100[/latex]

As a percentage of TEM (total exposure measure, used for the leverage ratio):

[latex]\text{MREL (TEM)} = \frac{\text{Own Funds} + \text{Eligible Liabilities}}{\text{TEM}} \times 100[/latex]

The institution must meet the MREL requirement under both measures. The binding constraint is whichever produces the higher required amount of own funds and eligible liabilities in absolute terms.

The MREL requirement itself is set by the resolution authority and consists of two components: a loss absorption amount (LAA), broadly equivalent to the minimum capital requirements, and a recapitalization amount (RCA), which ensures the institution can be recapitalized to meet its capital requirements post-resolution. For institutions with a liquidation strategy (no resolution), the recapitalization amount is typically zero, and MREL equals the loss absorption amount.

What Counts as Eligible Liabilities

Not every liability on the balance sheet counts toward MREL. Eligible liabilities must meet specific criteria under Article 45b BRRD and Article 72b CRR (for TLAC-eligible instruments). The main requirements are:

  • The liability must be issued and fully paid up
  • It must not be owed to, secured by, or guaranteed by the institution itself
  • The purchase was not funded directly or indirectly by the institution
  • It has a remaining maturity of at least one year (or the contractual provisions do not give the holder a right to repayment within one year)
  • It does not arise from a derivative
  • It does not arise from a deposit that is preferred under the national insolvency hierarchy
  • For instruments governed by third country law: it includes the Article 55 contractual recognition clause

The subordination requirement adds another layer. For resolution entities, a portion of the MREL must be met with subordinated instruments (own funds plus instruments that are contractually or structurally subordinated to excluded liabilities). The exact subordination requirement depends on the resolution authority’s decision and may reference the thresholds in Article 45b(4) and (5) BRRD.

For a more detailed treatment of how to manage changes to MREL-eligible instruments (including reductions, repurchases, and calls), see our article on MREL Prior Permission for Own Funds Reduction.

Internal vs External MREL

External MREL

External MREL applies to resolution entities, which are the top-level entities within a resolution group (typically the EU parent undertaking or, in an MPE strategy, each separate resolution entity). External MREL is met with instruments issued to external creditors (not group entities). The resolution authority sets the requirement at the consolidated resolution group level.

The reporting covers the consolidated position: total own funds and eligible liabilities of the resolution group, the TREA and TEM at consolidated level, and the resulting ratios. Templates M 01.00, M 02.00, M 04.00, M 05.00, and M 07.00 capture this information.

Internal MREL

Internal MREL applies to entities within a resolution group that are not the resolution entity (typically material subsidiaries). These entities must hold own funds and eligible liabilities issued to the resolution entity. The purpose is to preposition loss-absorbing capacity within the group.

Article 45f BRRD sets out how internal MREL is determined. The resolution authority sets the internal MREL for each subsidiary in coordination with the resolution authority of the resolution entity, typically through a joint decision in the resolution college. The amount is calibrated to ensure the subsidiary can absorb losses and be recapitalized without triggering the entire group’s resolution.

Template M 06.00 captures internal MREL. It reports the internal MREL requirement, the available resources (own funds and eligible liabilities issued to the resolution entity), and the gap or surplus.

In practice, internal MREL creates a layer of complexity for group reporting. The resolution entity must ensure that its external MREL covers both its own loss absorption needs and the prepositioning of internal MREL to subsidiaries. The subsidiaries must report their individual internal MREL compliance. The group’s finance function needs to coordinate both perspectives.

MREL Disclosure Requirements

In addition to regulatory reporting (submitted to authorities), institutions must publicly disclose their MREL positions. The disclosure templates are in Annex V of ITS 2021/763 and include EU KM2 (key metrics), EU TLAC1 (composition of eligible instruments), EU TLAC2 (creditor ranking), and EU TLAC3 (entity-level detail for groups).

The disclosure frequency aligns with the Pillar 3 disclosure calendar: quarterly for large and listed institutions, semi-annually for significant institutions, and annually for smaller institutions (though the exact frequency may depend on NCA guidance). The disclosure templates map directly to the reporting templates (the EBA published a mapping document between M templates and EU KM2/TLAC templates), which means the same data feeds both. Getting the reporting right means the disclosure is largely an extraction exercise.

Luxembourg Reporting Chain

For Banking Union Institutions (SRM Scope)

Luxembourg credit institutions subject to the Single Resolution Mechanism (SRM) have their MREL set by the SRB (Single Resolution Board), in consultation with the CSSF. The MREL decision flows from the SRB through the CSSF to the institution. The institution reports MREL data to the CSSF, which transmits it to the SRB and EBA.

In practice, the SRB drives the MREL calibration for significant institutions and for less significant institutions with a resolution strategy other than liquidation. The CSSF implements the SRB’s decisions at the national level and serves as the primary contact for reporting questions. For less significant institutions with a liquidation strategy, the CSSF may set the MREL directly, typically at the loss absorption amount only.

For Non-SRM Institutions

Investment firms and other institutions not in scope of the SRM have their MREL set by the CSSF acting as the national resolution authority. The reporting framework is the same (ITS 2021/763 templates), but the submission goes only to the CSSF, not to the SRB.

Practical Considerations

The CSSF expects MREL reporting to be submitted through the same infrastructure as COREP and FINREP. The XBRL taxonomy for MREL is part of the EBA’s broader reporting taxonomy. If your reporting system already handles COREP submissions, the MREL templates use the same technical framework.

One practical issue I have seen repeatedly: the MREL templates require data that does not naturally sit in the regulatory reporting function. Creditor ranking (M 02.00) requires input from legal and treasury. Third country law instruments (M 07.00) require input from the issuance and documentation team. Internal MREL (M 06.00) requires coordination with group-level treasury and the resolution planning function. Build these data feeds before the first reporting deadline, not during it.

Common Reporting Errors

Misclassifying Creditor Rankings

M 02.00 requires every liability to be classified by its ranking in the insolvency hierarchy. The most common error is misclassifying senior preferred bonds as senior non-preferred (or vice versa), particularly for instruments issued before the introduction of the senior non-preferred class in Luxembourg law (Law of 25 July 2018). Legacy instruments may need careful legal analysis to determine their correct ranking.

Maturity Bucketing Errors

M 04.00 requires residual maturity breakdowns (under 1 year, 1-2 years, 2+ years). The error occurs when callable instruments are bucketed by their contractual maturity rather than their earliest call or redemption date. If the instrument can be called within one year, it should generally be reported in the under-one-year bucket for resolution planning purposes. Consult your resolution authority on the treatment of call dates.

Missing Article 55 Clauses

Instruments governed by third country law must include the Article 55 contractual recognition clause to count toward MREL. If the clause is missing, the instrument should not be reported in M 05.00/M 07.00 as MREL-eligible. I have seen institutions include legacy English law instruments in their MREL calculation without verifying whether the issuance documentation was updated to include the Article 55 clause. This overstates MREL compliance.

Inconsistency Between MREL and COREP Own Funds

The own funds component of MREL (the numerator) must be consistent with the own funds reported in COREP. If your COREP C 01.00 reports CET1 of EUR 500m and your MREL M 01.00 shows a different figure for own funds (other than from legitimate MREL-specific adjustments), the resolution authority will flag the discrepancy. Cross-check these figures before submission.

Not Deducting Prior Permission Amounts

If the institution has received prior permission to reduce own funds or eligible liabilities (under Article 77-78 CRR or Article 78a CRR), the unused portion of that permission must be deducted from available MREL resources in the reporting. Failing to deduct these amounts overstates compliance. The instructions for M 04.00 explicitly reference “before the deduction of unused prior permission amounts.”

Frequently Asked Questions

How often do we submit MREL templates?

Quarterly, aligned with the COREP reporting calendar. Reference dates are 31 March, 30 June, 30 September, and 31 December. The ITS remittance dates are fixed: 19 May, 18 August, 18 November, and 18 February (approximately 49 days after each reference date).

Do all institutions report all M templates?

No. The scope depends on your entity type and resolution strategy. Resolution entities report M 01.00, M 02.00, M 03.00, M 04.00, and (if applicable) M 05.00 and M 07.00. Non-resolution entities within a group report M 06.00 for internal MREL. Institutions with a liquidation strategy (MREL equal to loss absorption only) may have simplified reporting. Your resolution authority confirms which templates apply to your entity.

Has the M 03.00 template changed?

Yes. M 03.00 was amended by CIR (EU) 2024/1618 to reflect the daisy chain framework and prior permission deduction requirements. It remains part of the active reporting framework. If your reporting system uses an older version of the M 03.00 template, update it to the version in the amended ITS 2021/763. M 03.00 captures the MREL requirement itself, complementing M 01.00 which reports the available resources.

What is the difference between the MREL reporting templates and the MREL disclosure templates?

The reporting templates (M 01.00 through M 07.00) are submitted to the competent authority confidentially. The disclosure templates (EU KM2, EU TLAC1, EU TLAC2, EU TLAC3) are published in Pillar 3 reports. The data content is largely the same (the EBA provides a mapping), but the format and audience differ. Get the reporting right and the disclosure follows.

How does internal MREL interact with external MREL for group reporting?

The resolution entity reports external MREL at the consolidated resolution group level. Individual subsidiaries report internal MREL on an individual basis. The resolution entity’s external MREL must be sufficient to cover both its own requirements and the prepositioning of internal MREL to subsidiaries. The group’s finance function must ensure consistency between these two perspectives.

What happens if we breach our MREL requirement?

A breach triggers notification obligations to the resolution authority and competent authority. The institution must submit a restoration plan. The resolution authority may take measures under Article 45k BRRD, including restricting distributions, requiring the institution to issue additional eligible instruments, or (in severe cases) triggering resolution planning measures. Early communication with the CSSF and SRB is critical if a breach is approaching.

Are MREL templates submitted in XBRL?

Yes. MREL templates are part of the EBA’s XBRL reporting taxonomy. The submission format is the same as for COREP and FINREP. If your institution already has a COREP/FINREP reporting pipeline, the MREL templates use the same technical infrastructure.

Related Articles

  • MREL Prior Permission for Own Funds Reduction – How to manage reductions in own funds and eligible liabilities, including the prior permission process under Articles 77, 78, and 78a CRR.
  • COREP Reporting Explained – The broader prudential reporting framework that MREL templates sit within. The own funds in COREP C 01.00 must reconcile with MREL M 01.00.
  • COREP Reporting Errors – Common submission mistakes that also affect MREL data quality, particularly own funds misstatements that propagate into MREL ratios.
  • FINREP Reporting Explained – Financial reporting that provides the liability-side data feeding into MREL creditor ranking and funding structure templates.

Key Takeaways

  • MREL reporting under ITS 2021/763 (as amended by CIR (EU) 2024/1618) consists of templates M 01.00 through M 07.00. M 03.00 reports the requirement itself and was amended (not deleted) in the latest revision. The scope depends on whether the entity is a resolution entity or a non-resolution entity within a group.
  • The MREL ratio is expressed two ways: as a percentage of TREA and as a percentage of TEM. The institution must meet the requirement under both measures.
  • Reporting is quarterly, aligned with COREP deadlines. Templates are submitted in XBRL to the CSSF, which transmits data to the SRB and EBA.
  • M 01.00 (key metrics) is the headline template. M 02.00 (creditor ranking) and M 04.00 (funding structure) are the most labor-intensive due to granular classification requirements.
  • Internal MREL (M 06.00) applies to non-resolution entities within a group. It must be coordinated with the resolution entity’s external MREL reporting.
  • Third country law instruments (M 05.00/M 07.00) require contract-level detail and verification of Article 55 bail-in recognition clauses.
  • Common errors include creditor ranking misclassification, maturity bucketing mistakes for callable instruments, and inconsistency between COREP own funds and MREL own funds figures.
  • MREL disclosure (EU KM2, EU TLAC1-3) uses the same data as the reporting templates. The EBA publishes a mapping between the two sets.

Sources and References

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.

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