EBA MREL Dashboard Q4 2025: How Resolution Reporting Teams Should Read the 25-29% RWA Benchmarks

ByOfficer

Last updated: June 2026

A resolution reporting officer opens the new EBA MREL dashboard and reads that other banks carry a binding requirement of 24.6% of risk-weighted assets while G-SIIs sit at 28.9%. The wrong move is to treat those numbers as a target your own institution should hit. They are weighted averages across a balanced sample of banks earmarked for resolution. Your binding requirement is whatever your resolution authority set in its individual decision, and that decision is what your M-templates have to reconcile to.

The EBA MREL dashboard for Q4 2025, published on 22 June 2026, is a read-across tool, not a rulebook. It aggregates the minimum requirement for own funds and eligible liabilities (MREL) that resolution authorities reported to the EBA, with a reference date of 31 December 2025. For teams filing resolution reporting under the Bank Recovery and Resolution Directive, the value is in the benchmarks, not in any single headline figure. This is a change note on that one publication.

Related reading: MREL reporting requirements: templates, frequency and what your resolution authority expects

What the EBA MREL dashboard actually measures

The headline figures cover external MREL as a percentage of the total risk exposure amount (TREA), including the combined buffer requirement. For Q4 2025 the weighted-average binding requirements are 28.9% for global systemically important institutions, 28.4% for top-tier and “fished” banks, and 24.6% for other banks. The subordination requirement, the part met with instruments ranking below ordinary senior, averages 21.4% of TREA for G-SIIs and 21.7% for top-tier and fished banks.

One detail teams miss is what “binding requirement” means here. MREL is calibrated on two legs: a TREA-based requirement plus the combined buffer requirement, and a total-exposure-measure (TEM) leg, which is the leverage-ratio denominator. The binding figure is the higher of the two, expressed back in TREA terms. A bank can look comfortable against the TREA leg and still be bound by the TEM leg, so the institutions worth watching are those constrained by the leverage ratio rather than by risk weights.

The sample is also narrower than it looks. The dashboard draws on 322 institutions with external MREL decisions reported to the EBA, of which 303 are covered, plus 176 with internal MREL decisions, of which 168 are covered. These are banks with a resolution strategy other than liquidation, so reading the averages as “what banks generally hold” misreads the population.

External versus internal MREL: do not compare the wrong number

The dashboard separates external MREL, set at the resolution entity level, from internal MREL (iMREL), down-streamed to non-resolution entities inside a resolution group. For Q4 2025 the weighted-average binding iMREL requirement is 25.9% of TREA for entities under a global systemically important resolution entity, 24.6% for those under a top-tier or fished resolution entity and 21.3% for those under an “other” resolution entity.

The common error in a multi-entity group is matching a subsidiary’s iMREL to the parent’s external requirement and concluding the subsidiary is under-resourced. The two are calibrated independently, and the dashboard categorises non-resolution entities by the type of their resolution entity precisely so the comparison stays like-for-like. Single point of entry strategies dominate: 89% of resolution groups by number of decisions, and 85% by RWAs, use a single point of entry approach. That is why iMREL down-streaming is where the operational work concentrates for cross-border groups.

Where the dashboard data comes from in your reporting stack

The benchmarks are computed from resolution reporting templates, and the dashboard’s methodological annex names the cells, which makes it a reverse-engineering check on your own filings. TREA and the total exposure measure are taken from template M 01.00. Subordinated instruments come from M 02.00. Internal MREL eligible instruments and the internal TREA come from M 03.00. The binding requirement, the subordination requirement and the compliance date are pulled from M 20.00, which carries the resolution authority’s decision. The combined buffer requirement is taken across from COREP, specifically C 04.00 and C 02.00.

That COREP link trips teams up. The buffer is the combined buffer requirement from your COREP own funds reporting, not re-derived inside the resolution templates. If your COREP and large-exposures returns and your resolution templates disagree on the buffer, the MREL ratio the EBA computes will not match the one you expect, and the divergence usually traces back to a buffer-source mismatch rather than to the MREL instruments themselves.

Note one thing that has confused teams in past cycles. Template M 03.00 was not deleted from the framework. The reporting of MREL and TLAC by institutions sits in Commission Implementing Regulation (EU) 2021/763, amended by Commission Implementing Regulation (EU) 2024/1618, which applies from 27 December 2024. That amendment revised the M-templates and the disclosure templates; it did not remove internal MREL reporting.

Two reporting channels, two sets of deadlines

The MREL framework runs on two separate channels, on different remittance calendars. The institution-to-authority channel is governed by Commission Implementing Regulation (EU) 2021/763. Institutions report and disclose MREL and TLAC against quarterly remittance dates of 19 May, 18 August, 18 November and 18 February, for reference dates of 31 March, 30 June, 30 September and 31 December. Where a remittance day falls on a weekend or a public holiday in the relevant Member State, submission moves to the next working day. Public disclosure uses EU KM2, EU TLAC1, EU iLAC, EU TLAC2 and EU TLAC3 where applicable under Title II and Annex V of Commission Implementing Regulation (EU) 2021/763.

The authority-to-EBA channel feeds the dashboard. Resolution authorities report their MREL decisions to the EBA under Commission Implementing Regulation (EU) 2021/622, using template M 20.00. Commission Implementing Regulation (EU) 2026/519 of 10 March 2026 amends Commission Implementing Regulation (EU) 2021/622 and moves MREL-decision reporting by resolution authorities from an annual to a semi-annual cycle. Resolution authorities must transmit MREL applicable as of 30 June by 16 September of that year, and MREL applicable as of 31 December by 18 March of the following year. The amendment reflects, among other changes, Directive (EU) 2024/1174, the Daisy Chain Directive. For an institution the effect is indirect: a denser decisions dataset means peer benchmarks move more often, so do not read a shift in a peer-group average between releases as banks raising capital. It can simply be more decisions feeding the same sample.

How to use the benchmark data without misreading it

The dashboard’s value is comparison, not calibration. Start with your subordination position. The dashboard shows subordination requirements clustering around 21-22% of TREA for the largest banks, and flags that the requirement for top-tier banks under the Single Resolution Board’s remit is capped at 27% of TREA under BRRD Article 45b(4). If your estimate sits well outside the peer band for your size bucket, re-check the M 02.00 inputs before your resolution authority does. The same caution applies when you plan to redeem an eligible instrument: that runs through the separate MREL prior-permission process, not the dashboard.

Then read the resources mix, not just the totals. The dashboard breaks MREL resources into CET1, AT1, Tier 2, subordinated debt, senior non-preferred, senior unsecured, structured notes and MREL-eligible deposits. A bank meeting its requirement but leaning on senior unsecured has a different refinancing profile than one built on subordinated debt, and that profile interacts with liquidity and funding in resolution. The dashboard quantifies roughly EUR 231 billion of rollover needs across the sample over the next year.

Finally, treat the aggregate shortfall as context, not comfort. At EU and EEA level the dashboard reports the MREL level at 34.7% of TREA against a 28.1% requirement, leaving an aggregate shortfall to the end-state target of about EUR 0.4 billion. That near-closed aggregate hides individual banks still in transition: some retain extended periods to close shortfalls beyond 31 December 2024, and most shortfalls are measured against the end-state target. A small aggregate does not mean every reporting entity is in steady state.

Frequently Asked Questions

Is the 24.6% to 28.9% range a requirement my bank has to meet?

No. Those are weighted-average binding requirements across categories of banks earmarked for resolution, as a percentage of TREA including the combined buffer requirement. Your binding requirement is the one set in your resolution authority’s individual decision, carried in template M 20.00.

What is the difference between external and internal MREL in the dashboard?

External MREL is set at the resolution entity level. Internal MREL is down-streamed to non-resolution entities within a resolution group. The dashboard categorises internal MREL entities by the type of their resolution entity so the figures stay comparable. They are calibrated independently, so a subsidiary’s iMREL should not be benchmarked against a parent’s external requirement.

Why did the dashboard methodology cap top-tier subordination at 27%?

The cap reflects BRRD Article 45b(4), which limits the subordination requirement for top-tier banks under the Single Resolution Board’s remit to 27% of TREA. The dashboard applies that cap when computing the subordination requirement for those banks.

Did the reporting of MREL decisions change in 2026?

Yes, on the authority-to-EBA side. Commission Implementing Regulation (EU) 2026/519 of 10 March 2026 amends Commission Implementing Regulation (EU) 2021/622 and moves resolution authorities to a semi-annual reporting cycle. Resolution authorities must transmit MREL applicable as of 30 June by 16 September of that year, and MREL applicable as of 31 December by 18 March of the following year. The amendment reflects, among other changes, Directive (EU) 2024/1174, the Daisy Chain Directive.

When do institutions submit their own MREL and TLAC reports?

Institutions report under Commission Implementing Regulation (EU) 2021/763 against quarterly remittance dates of 19 May, 18 August, 18 November and 18 February, for reference dates of 31 March, 30 June, 30 September and 31 December. If a remittance day is a weekend or public holiday in the relevant Member State, it moves to the next working day.

Related Articles

Key Takeaways

  • The EBA MREL dashboard for Q4 2025, published 22 June 2026 with a 31 December 2025 reference date, shows weighted-average binding requirements of 28.9% of TREA for G-SIIs, 28.4% for top-tier and fished banks and 24.6% for other banks.
  • These are peer benchmarks, not targets. Your binding requirement is the one in your resolution authority’s M 20.00 decision.
  • The dashboard is computed from resolution templates M 01.00, M 02.00, M 03.00 and M 20.00, with the combined buffer requirement pulled across from COREP C 04.00 and C 02.00. Template M 03.00 was not deleted from the framework.
  • Institutions report MREL and TLAC under Commission Implementing Regulation (EU) 2021/763 (amended by Commission Implementing Regulation (EU) 2024/1618, applying from 27 December 2024), with quarterly remittance dates of 19 May, 18 August, 18 November and 18 February. Public disclosure uses EU KM2, EU TLAC1, EU iLAC, EU TLAC2 and EU TLAC3 where applicable under Title II and Annex V of that Regulation.
  • Commission Implementing Regulation (EU) 2026/519 of 10 March 2026 amends Commission Implementing Regulation (EU) 2021/622 and moves resolution-authority MREL-decision reporting to a semi-annual cycle (30 June reference date: submit by 16 September; 31 December reference date: submit by 18 March of the following year), reflecting Directive (EU) 2024/1174.
  • The subordination requirement for top-tier banks under the SRB’s remit is capped at 27% of TREA under BRRD Article 45b(4), and the aggregate EU and EEA shortfall to the end-state target is about EUR 0.4 billion.

Sources and References

  • European Banking Authority, press release, “The latest EBA MREL dashboard shows that MREL requirements range from 25% to 29% of risk-weighted assets depending on bank category” (22 June 2026): eba.europa.eu
  • European Banking Authority, MREL Dashboard – Q4 2025 (statistical annex and methodological guide): MREL Dashboard – Q4 2025 (PDF)
  • Commission Implementing Regulation (EU) 2021/763 of 23 April 2021 (ITS on supervisory reporting and public disclosure of MREL), EUR-Lex: eur-lex.europa.eu
  • Commission Implementing Regulation (EU) 2021/622 of 15 April 2021 (ITS on reporting of MREL decisions by resolution authorities to the EBA), EUR-Lex: eur-lex.europa.eu
  • Commission Implementing Regulation (EU) 2026/519 of 10 March 2026 amending Commission Implementing Regulation (EU) 2021/622 as regards the frequency of reporting and the information to be reported, EUR-Lex: eur-lex.europa.eu
  • European Banking Authority, “Implementing Technical Standards on disclosure and reporting of MREL and TLAC”: eba.europa.eu
  • Directive 2014/59/EU (BRRD) as amended by Directive (EU) 2019/879 (BRRD2), Articles 45 to 45m, EUR-Lex: eur-lex.europa.eu
  • Directive (EU) 2024/1174 (Daisy Chain Directive), EUR-Lex: eur-lex.europa.eu

Reading the dashboard as a control, not a scoreboard

The most useful habit a resolution reporting team can build around the EBA MREL dashboard is to treat each release as a reconciliation against its own filings. Pull your size bucket, your strategy type and your subordination band, then trace any surprise back through M 02.00, M 03.00 and the COREP buffer feed before it becomes a question from your resolution authority. The dashboard is at its best when it confirms your templates already say what you think they say.

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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