SRB 2025 Annual Report: What the Crisis-Readiness Shift Means for EU Banks’ Resolution and MREL Reporting

ByOfficer

Last updated: July 2026

A resolution plan that reads well and a bank that can actually be resolved over a weekend are two different things, and the SRB 2025 Annual Report is built around that gap. Published on 30 June 2026, the report tells resolution and MREL reporting teams that the Single Resolution Board has stopped measuring how far a bank has travelled towards resolvability and started measuring whether it is resolvable in practice. From the 2026 Resolution Planning Cycle, that change of question drives what your institution has to produce, document and be able to demonstrate on demand.

The practical stakes sit in the word “evidence”. A COREP own funds return or an MREL key-metrics template proves you hold the resources. It does not prove your internal resolution team can run a bail-in, mobilise collateral inside a weekend, or execute a transfer of a business line. The 2025 report ties resolution planning, resolvability self-assessment and MREL monitoring into one operational chain, and it expects banks to test the links. Treat the resolvability self-assessment as a form to close before the next reference date and you will fail the assessment the SRB now runs.

This article walks through what the report actually says, section by section: the scope of banks and plans in 2025, the methodology change from the 2026 cycle, the MREL numbers and how they are reported, the liquidity data exercise banks ran with the ECB, and what the CMDI reform does and does not change yet.

Related reading: our MREL reporting requirements guide.

What the SRB 2025 Annual Report actually reports

The Single Resolution Board is the central resolution authority for the Banking Union. Together with the 21 National Resolution Authorities it forms the Single Resolution Mechanism, established under Regulation (EU) No 806/2014 (the SRMR). The 2025 report marks the tenth anniversary of the SRM and the second year of the SRB’s medium-term strategy, SRM Vision 2028. That framing matters because Vision 2028 is where the shift from planning to operational crisis readiness comes from.

The scope numbers are concrete. In 2025 there were 115 banks under the SRB’s direct remit. Of those, 92 were earmarked for resolution and the remaining 23 had a liquidation strategy, mostly smaller institutions or specific business models. Resolution planning runs on an annual twelve-month Resolution Planning Cycle that begins each April. In 2025 the SRB was managing three cycles at once: closing the 2024 cycle, running the 2025 cycle, and preparing the 2026 cycle. The report states that 51 of the 101 plans in the 2025 cycle were adopted by 31 December 2025, with the remainder due in 2026, and that 50 of the 102 plans in the 2024 cycle were adopted during 2025.

Below the significant-institution layer, the SRB oversees the Less Significant Institutions handled directly by the NRAs. Resolution plans were required for 1,811 LSIs or LSI groups in the 2025 cycle. NRAs prepared or updated 261 of them, while 1,548 plans under simplified obligations from earlier cycles remained valid. Out of all those LSIs, 61 were earmarked for resolution; for most, the preferred strategy remained liquidation under normal national insolvency proceedings. Germany alone accounts for 1,074 of the LSI plans and Luxembourg for 41, which tells you how uneven the resolution-planning workload is across the Banking Union.

From progress towards resolvability to evaluating resolvability

The single most important line for reporting teams is buried in the resolvability section: following the end of the Expectations for Banks implementation phase, the SRB updated its resolvability assessment methodology, to apply from the 2026 cycle. The methodology moves from assessing progress towards resolvability to evaluating resolvability. The report also flags a stronger focus on variant strategies, in particular those involving transfer tools, so that a bank is prepared across a wider range of crisis scenarios rather than only its preferred one.

Here is where teams read the change too narrowly. The old approach let a bank show a trajectory: capabilities under construction, gaps with a remediation date, progress year on year. The new approach asks a binary operational question at the reference date. Can this capability be executed now? The deliverable is now the working capability itself, not a roadmap towards it. That reframing is designed to make comparability across the Banking Union sharper, because a “50 percent complete” self-assessment means very different things at two different banks, while “the transfer playbook was tested and worked” does not.

The SRB built the machinery to hold banks to that standard. It introduced a Single Planning Process under Vision 2028 that integrates resolution planning, testing and crisis-readiness work into one sequence, from global priority setting to bank-specific priority letters. The 2026 priority letters went to bank CEOs in October 2025. For the 2025 cycle, the common testing priorities were narrow and practical: a walkthrough on financial market infrastructure contingency plans to test continued access to FMI services, and a dry run on the Joint Liquidity Template to test liquidity and funding in resolution.

Resolvability self-assessment and testing: what banks must now produce

Two pieces of operational guidance published in 2025 turn the methodology into concrete deliverables. In August 2025 the SRB published operational guidance for banks on resolvability self-assessment. It sets out the capabilities a bank is expected to maintain to be resolvable and introduces a standardised self-assessment report so that banks document resolvability in a consistent way across the sector. In September 2025 the SRB followed with operational guidance on resolvability testing, covering how banks prepare, perform, document and follow up on bank-led tests, including governance, internal testing plans and test environments.

The guidance names the test methods explicitly: desktop exercises, walkthroughs, dry runs including operational and management simulation, and drills. These are not interchangeable labels. A walkthrough talks through a process; a dry run executes it against a test environment and a clock. When the SRB asks a bank to demonstrate a capability, the method it specifies tells you how much evidence you have to generate and how much of your operational data has to be real rather than illustrative.

Testing is now scheduled, not ad hoc. Throughout 2025 the internal resolution teams prepared the first iteration of multi-annual testing programmes for banks. Each programme combines common tests that apply across the Banking Union with bank-specific tests, and mixes bank-led exercises with authority-led supervisory examinations. Alongside these, the SRB launched its first on-site inspections for resolvability, concluding four in 2025 and scheduling more for 2026, coordinated with the ECB to limit duplication for the industry.

I have watched teams treat a resolvability self-assessment as a document to be closed before the next reporting reference date. The August 2025 guidance closes that door. The standardised self-assessment report has to be backed by capabilities the internal resolution team can put on a testing programme, and an on-site inspection can now check whether the capability behind the tick-box exists. If your resolvability evidence lives only in a slide deck, the multi-annual testing programme is where that shows.

MREL in 2025: full compliance, and why that is not the whole story

MREL is the loss-absorbing and recapitalisation capacity that makes resolution possible, so it sits at the centre of any crisis-readiness assessment. The headline number in the 2025 report is that, as of the first half of 2025, the average final MREL target including the combined buffer requirement for resolution entities under the SRB’s remit stood at 27.9 percent of the Total Risk Exposure Amount. All entities, both resolution and non-resolution, complied with their applicable requirements.

The report also states that the MREL shortfall against final external targets, including the combined buffer requirement, was below EUR 0.3 billion as of the first half of 2025, or 0.01 percent of TREA, and that this residual sits with entities still inside transitional periods to reach their final targets. Read those two statements together and the nuance becomes the point. “All entities complied” is measured against the requirement applicable at the date, which for some banks is still a transitional target. The near-zero residual is measured against the final target. A bank can be fully compliant today and still be building towards its end-state MREL, and the reporting has to keep those two views distinct.

This is where the number gets misused. A 27.9 percent Banking Union average is a weighted figure, not a floor and not a target any single bank should benchmark itself against. MREL is set bank by bank by the resolution authority, and the level depends on the resolution strategy, the bank category and the subordination requirement. For the wider EU picture, including banks outside the Banking Union, the EBA runs its own series; the EBA MREL dashboard reports requirements in a broad band by bank category and is the better reference for cross-jurisdiction comparison. Do not read the SRB’s single weighted average as your institution’s requirement.

The distinction between external and internal MREL runs through the reporting. External MREL applies to resolution entities and is set at the consolidated level of the resolution group, met with own funds and eligible liabilities the resolution entity issues externally. Internal MREL applies to non-resolution entities, the subsidiaries where the plan anticipates write-down and conversion, and is set at individual or sub-consolidated level. The SRB set targets for all resolution groups in its remit and internal targets for the relevant subsidiaries. Its MREL policy was last updated in 2024 and has stayed stable since, with only a limited review flagged for the future in light of the CMDI reform.

How MREL gets reported: the CIR 2021/763 templates and the daisy-chain amendment

The SRB’s dashboards and monitoring rest on a defined reporting stack, and knowing which template feeds which number saves reconciliation pain. The legal instrument is Commission Implementing Regulation (EU) 2021/763 of 23 April 2021, the implementing technical standards for supervisory reporting and public disclosure of MREL and TLAC under the Capital Requirements Regulation and the Bank Recovery and Resolution Directive. The SRB’s own H1 2025 MREL dashboard, published on 7 November 2025, states that it draws on the CIR 2021/763 templates, COREP reports, and the SRB’s quarterly data collection.

The templates that matter for MREL reporting teams include M 01.00, the key metrics for MREL and TLAC (KM2); M 02.00, MREL and TLAC capacity and composition (TLAC1); M 03.00, internal MREL and internal TLAC (ILAC); M 04.00, the funding structure of eligible liabilities (LIAB-MREL); M 06.00, creditor ranking (RANK); and M 07.00, instruments governed by third-country law (MTCI). A recurring error is to assume M 03.00 was deleted when internal reporting was overhauled. It was not. Commission Implementing Regulation (EU) 2024/1618 of 6 June 2024 amended CIR 2021/763 to reflect the daisy-chain deduction framework introduced by Regulation (EU) 2022/2036, and M 03.00 was amended, not removed. It is still the internal MREL template the SRB relies on for non-resolution entities.

When a resolution change lands on my desk, the first thing I check is the reference date and the remittance clock on the M 01.00 key-metrics return, because a methodology shift that leaves the template structure untouched still changes what the numbers have to prove. The 2026 resolvability methodology does not rewrite CIR 2021/763. It changes the evidentiary weight behind the figures: the same KM2 number now sits next to a tested capability rather than a remediation plan. Reconciling the M 01.00 own funds components against your COREP submission remains the baseline hygiene check, and a mismatch there is still the fastest way to draw a query.

Public MREL disclosure for SRB-remit banks is a separate obligation from supervisory reporting. It runs under Title II of CIR 2021/763 itself, the disclosure templates that implement Article 45i(3) of the BRRD, not the Title I reporting templates you file to the SRB, and the reporting side is not a substitute for it. If your team maps the supervisory templates but leaves the Pillar 3-style MREL disclosure to another workstream without reconciling the two, the numbers can diverge, and a divergence between what you report to the SRB and what you disclose publicly is exactly the kind of inconsistency the SRB’s quality assurance is built to catch.

Liquidity and funding in resolution: the five-day data exercise

Capital capacity is only half of resolvability. A bank can be solvent on paper and still fail because it cannot fund itself through the resolution weekend. The 2025 report puts real weight on this. Banks continued to work on the three liquidity principles in the Expectations for Banks: estimating liquidity and funding needs in resolution, measuring and reporting the liquidity situation in resolution, and identifying and mobilising collateral during and after resolution.

The concrete test came in November 2025, when banks were asked to deliver a standardised set of data points on their liquidity position and funding sources for five consecutive days, as a joint exercise with the ECB. The focus fell on the time a bank needs to mobilise its collateral. The SRB is measuring elapsed time to turn eligible assets into usable liquidity. A collateral pool that takes three days to mobilise is a different resolvability profile from one that mobilises overnight, even if the euro amounts match.

This work is still moving. In May 2026 the SRB launched a consultation on updated operational guidance on liquidity and funding in resolution, to fold in the lessons from these exercises. Teams that ran the five-day data pull in November 2025 will recognise the gaps that consultation is trying to close. For the mechanics of how the SRB frames liquidity and funding expectations, the SRB liquidity and funding in resolution guidance sets out the underlying principles in more detail.

Transfer strategies and operational continuity

The report’s emphasis on variant strategies shows up in two policy updates that reporting and resolution teams should track. The SRB updated its operational guidance on separability and transferability, adding a framework for Transfer Playbooks and an annex on testing to support demonstration of transfer capabilities, and consolidating the guidance around the Separability Analysis Report. The report is explicit that this update does not introduce new requirements; it restructures existing expectations towards a more testable and proportionate approach. That distinction matters when you scope a project: this is a re-organisation of what you already owe, aligned to the self-assessment guidance, not a new data burden.

On operational continuity in resolution, the SRB published an updated policy in the first quarter of 2025, aligned with the Digital Operational Resilience Act, which itself amended the Bank Recovery and Resolution Directive, and with the EBA guidelines on improving resolvability. If your institution has a DORA programme and a resolution programme running on separate tracks, the OCIR update is the seam where they meet, because operational continuity of critical services in resolution now has to be consistent with your DORA arrangements.

What CMDI changes, and what it does not change yet

2025 also delivered the political agreement on the Crisis Management and Deposit Insurance reform, and the framework has since been published. The reform reached the Official Journal on 20 April 2026 as three instruments adopted on 30 March 2026: Regulation (EU) 2026/808 amending the SRMR, Directive (EU) 2026/806 amending the BRRD, and Directive (EU) 2026/804 amending the Deposit Guarantee Schemes Directive. The SRMR regulation entered into force on 10 May 2026 and applies from 11 May 2028, with some SRMR provisions becoming applicable earlier, in 2026. The reform is aimed at widening the resolution toolkit for smaller and medium-sized banks and introduces a harmonised approach for Deposit Guarantee Schemes to contribute to resolution funding. You can follow the full timeline in our note on the CMDI reform’s publication in the Official Journal.

The common error here is to assume CMDI changes MREL reporting now. It does not. The SRB’s own MREL policy remains the 2024 version, and the report flags only a limited future review of that policy in light of CMDI, not an immediate rewrite. With general application in 2028, the reporting mechanics you run in 2026 and 2027 are still governed by the existing SRMR articles and CIR 2021/763. The prudent reading is to treat CMDI as a planning input for 2027 and 2028, keep watching which SRMR provisions switch on early in 2026, and not to re-engineer MREL returns in anticipation of rules that are not yet applicable.

Frequently Asked Questions

When was the SRB 2025 Annual Report published, and what is its headline message?

The report was published on 30 June 2026. Its central message is a shift from resolution planning to tested crisis readiness: the SRB now evaluates whether banks are resolvable in practice rather than tracking their progress towards resolvability, and this new methodology applies from the 2026 Resolution Planning Cycle.

What is the average MREL target for banks under the SRB’s remit?

As of the first half of 2025, the average final MREL target including the combined buffer requirement for resolution entities under the SRB’s remit was 27.9 percent of the Total Risk Exposure Amount. This is a weighted Banking Union average, not a requirement for any individual bank. MREL is set institution by institution based on the resolution strategy, bank category and subordination requirement.

Were there any MREL shortfalls in 2025?

The report states that all entities complied with their applicable requirements. The residual MREL shortfall against final external targets, including the combined buffer requirement, was below EUR 0.3 billion, or 0.01 percent of TREA, and is attributed to entities still within transitional periods to reach their final targets.

Which templates does the SRB use to monitor MREL?

MREL monitoring draws on the templates in Commission Implementing Regulation (EU) 2021/763, together with COREP data and the SRB’s quarterly data collection. The core templates include M 01.00 (key metrics, KM2), M 02.00 (capacity and composition, TLAC1), M 03.00 (internal MREL, ILAC), M 04.00 (funding structure, LIAB-MREL), M 06.00 (creditor ranking, RANK) and M 07.00 (third-country-law instruments, MTCI).

Was the internal MREL template M 03.00 deleted?

No. Commission Implementing Regulation (EU) 2024/1618 amended CIR 2021/763 to reflect the daisy-chain deduction framework introduced by Regulation (EU) 2022/2036. M 03.00, the internal MREL and internal TLAC template, was amended, not removed, and remains the SRB’s internal MREL reporting template for non-resolution entities.

What does resolvability testing require banks to do differently?

Banks are expected to maintain the capabilities set out in the August 2025 self-assessment guidance and to prepare, perform and document bank-led tests under the September 2025 testing guidance. Tests range from desktop exercises and walkthroughs to dry runs with operational and management simulation and drills. Internal resolution teams schedule these through multi-annual testing programmes, and the SRB can verify them through on-site inspections.

Does the CMDI reform change MREL reporting obligations now?

Not yet. The CMDI instruments were published on 20 April 2026, and the SRMR amending Regulation (EU) 2026/808 applies from 11 May 2028, with some SRMR provisions applicable earlier in 2026. The SRB’s MREL policy remains the 2024 version, with only a limited review flagged for the future. MREL reporting mechanics in 2026 and 2027 continue under the existing framework.

What was the November 2025 liquidity exercise?

Banks were asked to deliver a standardised set of data points on their liquidity position and funding sources for five consecutive days, in a joint exercise with the ECB. The exercise focused on how quickly banks can mobilise collateral. Elapsed time to convert eligible assets into usable liquidity is the metric that matters.

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Key Takeaways

  • From the 2026 Resolution Planning Cycle, the SRB evaluates whether banks are resolvable rather than tracking progress towards resolvability. The deliverable is a working, testable capability, not a remediation roadmap.
  • In 2025 there were 115 banks under the SRB’s remit, 92 earmarked for resolution and 23 for liquidation; 51 of 101 resolution plans in the 2025 cycle were adopted by year-end, with the rest due in 2026.
  • The average final MREL target including the combined buffer requirement for resolution entities was 27.9 percent of TREA in the first half of 2025, with all entities compliant with applicable requirements. This is a weighted Banking Union average, not an institution-specific target.
  • The residual MREL shortfall against final external targets was below EUR 0.3 billion (0.01 percent of TREA), sitting with banks still inside transitional periods.
  • MREL monitoring runs on CIR 2021/763 templates. M 03.00 (internal MREL) was amended by CIR 2024/1618 for the daisy-chain framework, not deleted.
  • Resolvability self-assessment (August 2025 guidance) and testing (September 2025 guidance) are now scheduled through multi-annual testing programmes and can be checked by on-site inspections. Four inspections were concluded in 2025.
  • The November 2025 liquidity exercise with the ECB measured how quickly banks could mobilise collateral over five consecutive days. Elapsed time to convert eligible assets into usable funding was the metric tracked.
  • CMDI does not change MREL reporting yet. Regulation (EU) 2026/808 applies from 11 May 2028, with some SRMR provisions earlier in 2026; the SRB’s 2024 MREL policy still governs, subject to a limited future review.

Sources and References

Preparing for the 2026 resolvability assessment

The reporting year that matters most is 2026, when the SRB’s new methodology first applies, rather than the 2025 the report looks back on. The practical work is to connect three things your institution probably runs on separate tracks: the MREL numbers in your CIR 2021/763 templates, the capabilities in your resolvability self-assessment, and the schedule in your multi-annual testing programme. The SRB’s 2025 report is a warning that they will be read together, and that a strong balance sheet does not compensate for an untested transfer playbook or a collateral pool that mobilises too slowly. Map the seams now, while CMDI is still a 2028 problem and the templates are stable, because the next thing the internal resolution team asks for will be evidence that the capability behind the number actually works.

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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