FSB Cross-Sectoral Resolution Planning: The ReSolve Signal for Banks

ByOfficer

On 9 July 2026, the Financial Stability Board put bank, financial-market-infrastructure and insurance resolution experts in the same room and told them to stop planning in parallel. The occasion was the FSB’s ReSolve event for its Cross-Border Crisis Management working groups, and the framing came from FSB Secretary General John Schindler: the financial system is not a set of isolated silos, so cross-sectoral resolution planning has to be built into how authorities think about failure.

For bank reporting teams, the remarks provide policy context for crisis preparedness. They do not mention MREL or TLAC reporting and do not state how authorities will interpret those returns.

The remarks create no new template, deadline or return. Schindler identified three cross-sectoral examples: bank distress appearing on an insurer’s balance sheet, a CCP default-management failure affecting clearing-member banks, and liquidity strains cascading across sectors. Any connection to specific bank returns, reporting fields or authority information requests is an interpretation and should be labelled as such.

This article walks through what the ReSolve remarks said, where they sit against the FSB Key Attributes and the EU resolution framework, the three contagion channels Schindler named, and what all of it does and does not change for a bank’s reporting stack today.

Related reading: SRB 2025 Annual Report: Resolution Crisis-Readiness and MREL Reporting

What the FSB actually said at ReSolve

The 9 July 2026 remarks are a speech, catalogued by the FSB under Press and Speeches, and they carry the standard caveat that the views are the Secretary General’s in his FSB role and do not necessarily reflect those of the FSB or its members. Treat them accordingly. They describe a direction of travel, not an adopted standard, and the FSB itself frames them that way.

Schindler’s central move was to bring together the members of all three resolution working groups, covering banks, financial market infrastructures and insurers, because that mix reflects how the FSB now thinks about the sector: as a deeply interconnected system rather than three separate books of work. After the Key Attributes were adopted in 2011, the FSB helped authorities build resolution frameworks sector by sector, and it says that work has largely paid off. Foundational frameworks are now in place across all three sectors, with members continuing to operationalise them. The next problem the FSB is naming is that vulnerabilities in one area propagate to others, often in new ways, so it wants one conversation on interconnected issues instead of several parallel ones.

A common misreading is already worth heading off. This is not the FSB announcing that banks must file a new cross-sectoral report. There is no cross-sectoral resolution return in the speech, and none is promised. What the FSB flagged is a strategic review of its crisis preparedness activities, launched on 19 February 2026, which will examine whether its approach across sectors and across the crisis-preparedness continuum remains fit for purpose. The FSB has not announced any reporting consequence or committed to producing a sectoral standard as an outcome of the review.

From sector silos to one system: the cross-sectoral resolution planning shift

To see why the FSB is changing emphasis rather than changing rules, it helps to place the remarks against the architecture that already exists. The FSB Key Attributes of Effective Resolution Regimes for Financial Institutions are the umbrella standard, first issued in 2011 and reissued as a revised version in April 2024 that folded in additional guidance on the financial resources and tools needed for the orderly resolution of a central counterparty. The Key Attributes are the FSB’s international standard for effective resolution regimes. In the EU, binding bank and CCP resolution frameworks are established by BRRD, the SRM Regulation and Regulation (EU) 2021/23 within a broader international policy framework.

The EU built its version of this sector by sector too. Banks came first, through Directive 2014/59/EU, which subjects credit institutions and investment firms to resolution planning, resolvability assessment and the minimum requirement for own funds and eligible liabilities. Even that directive recognised contagion in its own recitals: the insolvency of one entity in a group can rapidly impair the solvency of the whole group, so authorities need tools that produce a consistent resolution scheme for the group rather than for a single legal entity. Central counterparties and central securities depositories were explicitly left to a separate legislative initiative, which arrived as the CCP recovery and resolution regime. The interconnection point the FSB is now pressing was visible in the legislation from the start; what has changed is the FSB’s insistence that authorities read across those regimes at the same time.

The FSB’s own stocktake supports the “frameworks are built, now make them work together” framing. Its 2025 Resolution Report, published on 21 January 2026 under the title From Plans to Practice: Operationalising Resolution, records that effective resolution frameworks are largely in place, summarises resolvability assessment results for global systemically important banks and CCPs, reports updated recovery and resolution planning guidance for insurers, and lists the challenges it still wants to solve, including funding in resolution and cross-border bail-in execution. Cross-sectoral operationalisation is the connective theme.

The three contagion channels the FSB named

Schindler gave three concrete examples of how distress travels between sectors, and each maps onto a piece of the reporting and resolution framework that a bank team already touches.

The first example is a bank’s distress appearing on an insurer’s balance sheet. Schindler did not specify the instruments involved or connect this example to MREL or TLAC reporting. Under Commission Implementing Regulation (EU) 2021/763, template M 04.00 reports eligible liabilities by liability type and residual maturity; the standard templates do not contain a holder-sector profile. Analysis of insurer holdings would therefore require another dataset or an authority-specific information request.

The second example is a failure in a CCP’s default-management process affecting banks that are clearing members. Regulation (EU) 2021/23 provides resolution tools including reduction of gains payable to non-defaulting clearing members, resolution cash calls, and the position allocation tool exercised through partial or full termination of contracts. For bank resolvability, the FSB’s 2025 G-SIB resolvability questionnaire expressly covered continuity of access to FMI services; neither the speech nor the EU CCP Regulation states that every bank resolution plan must model the CCP’s entire default waterfall. Our coverage of the ESMA CCP default simulation for clearing members and the 6th ESMA CCP stress test provides further operational context.

The third example is liquidity strain cascading across the system. The FSB’s 2025 Resolution Report identifies funding in resolution as an ongoing implementation challenge. The SRB opened a consultation on updated operational guidance on 11 May 2026, stating that it proposed targeted amendments to existing expectations and no new deliverables; the consultation deadline was 6 July 2026. As at 10 July 2026, the official SRB material still labels the document ‘FOR CONSULTATION’, so it should not be presented as final guidance.

Where crisis-readiness meets the reporting stack

The ReSolve remarks do not change current reporting obligations. They also do not state that authorities will reinterpret existing returns. Any cross-sectoral reporting consequence would require a later standard, legal instrument, published guidance or authority-specific request.

The global anchor for bank loss absorbency is the FSB’s November 2015 Total Loss-Absorbing Capacity Principles and Term Sheet. The general minimum was 16 percent of resolution-group risk-weighted assets and 6 percent of the leverage-ratio exposure measure from 1 January 2019, rising to 18 percent and 6.75 percent from 1 January 2022. G-SIBs headquartered in emerging market economies had later phase-in dates of 1 January 2025 and 1 January 2028, subject to the standard’s acceleration provision. The EU implements TLAC for G-SIIs through the Capital Requirements Regulation; for a G-SII resolution entity, MREL consists of the TLAC requirement plus any additional MREL amount under Article 45d(1) BRRD.

Commission Implementing Regulation (EU) 2021/763 sets the EU reporting and disclosure ITS for MREL and TLAC. For resolution entities within scope, M 01.00, M 02.00, M 04.00, M 06.00 and M 07.00 are reported quarterly, subject to the individual and consolidated reporting rules in Articles 3 and 4. The Regulation’s reporting requirements applied from 28 June 2021, while the BRRD II public-disclosure provisions applied from 1 January 2024. Commission Implementing Regulation (EU) 2024/1618, applicable from 27 December 2024, updated the templates for indirect holdings of internal MREL and TLAC instruments, liquidation-entity changes and the reporting and disclosure treatment of prior permissions.

The ReSolve remarks do not add fields to the EU templates and do not state that authorities will reinterpret MREL or TLAC returns. Commission Implementing Regulation (EU) 2021/763 requires, among other items, quarterly reporting of key metrics in M 01.00, composition in M 02.00, funding structure by liability type and maturity in M 04.00, creditor ranking in M 06.00 and third-country-law instruments in M 07.00 for resolution entities within scope. Those templates do not provide a holder-sector breakdown. Banks should distinguish the speech’s cross-sectoral policy message from the binding data requirements in the ITS. Our guide to MREL reporting requirements sets out the template mechanics in full.

MREL and TLAC overlap but are not identical. Directive 2014/59/EU requires MREL information to be reported to competent and resolution authorities, while Regulation (EU) No 575/2013 requires TLAC information to be reported to competent authorities. Resolution authorities receive TLAC information for G-SIIs through the aligned MREL reporting framework. Resolution authorities set institution-specific MREL, whereas the CRR establishes the TLAC minimum for G-SIIs. COREP own-funds data can be an input, but eligibility rules and the resolution-group perimeter require separate controls. The EBA MREL dashboard provides aggregated MREL data.

The strategic review of crisis preparedness and what to watch

The most forward-looking line in the remarks is the strategic review of the FSB’s crisis preparedness activities. Schindler described it as a chance to step back and ask whether the FSB’s approach across sectors, and across the continuum from recovery through early intervention and resolution to post-stabilisation restructuring, is still fit for purpose. Understanding cross-sectoral interconnections and how they play out in a crisis is meant to be central to that review.

For reporting teams, the review identifies the crisis-preparedness stages the FSB will examine: early intervention, recovery, resolution and post-stabilisation restructuring. The FSB has not said where any future expectation would land and has not announced a reporting return, information request or sectoral standard as an outcome. Operational changes should follow a published consultation, standard, legal instrument or authority-specific instruction.

It is worth separating what is committed from what is signalled. The strategic review is committed; it has been launched. Any specific reporting change is signalled at most, and only indirectly, through the review’s eventual conclusions and the sector-specific standards that would carry them. A reporting team that rebuilds its data model on the strength of the speech alone would be acting on a direction of travel, not a rule.

What this does and does not mean for a bank reporting team today

Take the practical position first. Nothing in the reporting calendar moves because of ReSolve. MREL and TLAC reporting under the 2021 implementing standards continues on its existing quarterly rhythm, resolvability self-assessments continue on their existing cadence, recovery plans continue on their existing cycle, and the banking union’s calibration and prior-permission processes run unchanged. A team that files these today should keep filing them exactly as before.

The speech does not establish that resolvability assessments or supervisory dialogue will request holder-sector, CCP-waterfall or funding-dependency data. A bank may use the remarks as an internal prompt to review cross-sectoral dependencies in its resolution-planning, FMI-continuity and liquidity capabilities, but any external submission should be based on a binding rule, published guidance or an authority-specific request.

The wider EU reform backdrop is legally separate from the FSB speech. Regulation (EU) 2026/808 entered into force on 10 May 2026, generally applies from 11 May 2028 and specifies a list of provisions applying from 11 June 2026. It amends the SRM Regulation regarding early intervention measures, conditions for resolution and funding of resolution action. Our summary of the CMDI Official Journal publication covers the timeline. The Regulation is not evidence that the ReSolve speech changes how MREL or TLAC reporting data must be interpreted.

One caution on jurisdiction. The FSB standard is global, but the reporting instruments are not. EU and banking-union banks report MREL and TLAC under the EU implementing standards and to the SRB or national resolution authorities; a UK bank reports its equivalent to the Bank of England under the UK resolution regime, which follows the same FSB Key Attributes but is set domestically and diverges in detail. Reading an FSB signal as if it flowed directly into your local return, without checking the instrument that actually binds you, is the fastest way to misfile.

Frequently Asked Questions

Does the FSB’s 9 July 2026 ReSolve speech create a new reporting obligation for banks?

No. The remarks are a speech that signals direction. They introduce no template, deadline or return. Any reporting change would come from a later FSB workstream or a sector-specific standard following the strategic review of crisis preparedness, not from the speech itself.

What is the difference between cross-sectoral resolution planning and the resolution planning banks already do?

Ordinary resolution planning assesses whether a single bank or banking group can be resolved in an orderly way. Cross-sectoral resolution planning asks how distress travels between banks, financial market infrastructures and insurers, so a bank’s plan is read against contagion channels outside its own perimeter, such as a clearing house’s default management or an insurer’s holdings of the bank’s debt.

Which reporting standards govern MREL and TLAC in the EU?

Commission Implementing Regulation (EU) 2021/763 lays down the implementing technical standards for supervisory reporting and public disclosure of MREL and TLAC, using templates such as M 01.00 for key metrics and M 02.00 for the composition of own funds and eligible liabilities on a quarterly frequency. It was amended by Commission Implementing Regulation (EU) 2024/1618 to reflect multiple-point-of-entry groups and the daisy-chain framework.

Where does the FSB TLAC standard fit against EU MREL?

The FSB’s November 2015 TLAC standard set general minimums of 16 percent of resolution-group risk-weighted assets and 6 percent of the leverage-ratio exposure measure from 1 January 2019, rising to 18 percent and 6.75 percent from 1 January 2022. G-SIBs headquartered in emerging market economies had later phase-in dates of 1 January 2025 and 1 January 2028. In the EU, the CRR implements TLAC for G-SIIs, while resolution authorities set institution-specific MREL under BRRD and the SRM framework.

How does a central counterparty’s failure reach a bank’s resolution plan?

Regulation (EU) 2021/23 provides CCP resolution tools including reduction of gains payable to non-defaulting clearing members, resolution cash calls, and the position allocation tool exercised through partial or full termination of contracts. For a clearing-member bank, the directly evidenced bank-resolution consideration is continuity of access to FMI services; the FSB speech does not prescribe how the bank must model the CCP’s default waterfall.

Should a reporting team change anything now?

Continue filing under the current legal instruments and authority instructions. The speech itself does not require holder-sector, CCP-waterfall or funding-dependency data. Banks may review those dependencies internally, but any external reporting change would require a binding rule, published guidance or an authority-specific request.

Does this affect UK banks the same way?

The Key Attributes are an international standard rather than a directly binding global reporting instrument. UK obligations are set domestically through Bank of England and PRA instruments and differ from the EU ITS. Current UK rules must be checked directly: 2026 policy changes removed specified templates with immediate effect and introduce revised MREL templates from 1 January 2027. The ReSolve speech itself creates no UK reporting obligation.

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Key Takeaways

  • The FSB’s 9 July 2026 ReSolve remarks call for cross-sectoral thinking but create no reporting rule and do not mention MREL or TLAC reporting.
  • The FSB brought together its bank, FMI and insurer resolution working groups because it views the financial sector as an interconnected system rather than isolated silos.
  • Schindler identified three examples: bank distress appearing on an insurer’s balance sheet, CCP default-management failure affecting clearing-member banks, and liquidity strains cascading across sectors.
  • Commission Implementing Regulation (EU) 2021/763 continues to govern EU MREL and TLAC reporting. Its templates cover metrics, composition, liability type, maturity, creditor ranking and third-country-law instruments, but not holder-sector profiles.
  • The FSB launched its strategic review on 19 February 2026. It has not announced a new return, information request or sectoral reporting standard as an outcome.
  • The SRB’s May 2026 liquidity and funding document remained a consultation as at 10 July 2026 and should not be described as final guidance.
  • Binding obligations remain jurisdiction-specific. EU institutions must follow EU law and resolution-authority instructions; UK firms must follow current Bank of England and PRA instruments.

Sources and References

  • Financial Stability Board, “Exploring cross-sectoral interconnections in resolution planning” (remarks by John Schindler, FSB Secretary General, 9 July 2026): fsb.org
  • Financial Stability Board, “2025 Resolution Report: From Plans to Practice: Operationalising Resolution” (21 January 2026): fsb.org
  • Financial Stability Board, “Total Loss-Absorbing Capacity (TLAC) Principles and Term Sheet” (November 2015): fsb.org
  • Financial Stability Board, “Key Attributes of Effective Resolution Regimes for Financial Institutions” (revised version 2024): fsb.org
  • Directive 2014/59/EU (Bank Recovery and Resolution Directive): eur-lex.europa.eu
  • Regulation (EU) No 806/2014 (Single Resolution Mechanism Regulation): eur-lex.europa.eu
  • Commission Implementing Regulation (EU) 2021/763 (ITS on MREL and TLAC reporting and disclosure): eur-lex.europa.eu
  • Commission Implementing Regulation (EU) 2024/1618 (amending the MREL and TLAC reporting ITS): eur-lex.europa.eu
  • Regulation (EU) 2021/23 (CCP Recovery and Resolution Regulation): eur-lex.europa.eu
  • Regulation (EU) 2026/808 (CMDI amendment to the SRM Regulation): eur-lex.europa.eu
  • Financial Stability Board, “Strategic review of FSB crisis preparedness activities” (19 February 2026): fsb.org
  • Directive (EU) 2019/879, including the MREL public-disclosure application date: eur-lex.europa.eu
  • Single Resolution Board, consultation on updated operational guidance on liquidity and funding in resolution (11 May 2026): srb.europa.eu
  • Bank of England and PRA, PS9/26, “Resolution planning: Amendments to MREL reporting templates” (26 March 2026): bankofengland.co.uk

Reading resolution readiness as a system

The ReSolve remarks provide policy context rather than a new reporting lens. They ask FSB authorities to examine interconnections among banks, FMIs and insurers and make those interconnections central to the strategic review. The speech does not state that MREL or TLAC returns, resolvability self-assessments or recovery plans must be interpreted differently. Banks should keep current submissions aligned with binding rules and monitor the FSB review and local authority publications for concrete changes.

Last updated: July 2026

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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