SRB Resolution Communication Plan: The April 2028 Deadline

On 17 September 2026, the Single Resolution Board (SRB) published its Operational Guidance for Banks on Communication in Resolution, together with a Communication Testing Supplement to its resolvability testing guidance. The document turns a single line of the Single Resolution Mechanism Regulation into a build project: under Article 8(9)(n) of Regulation (EU) No 806/2014 (SRMR), a communication plan has to be prepared as part of resolution planning, and the SRB now spells out what that resolution communication plan, and the governance around it, are expected to contain.

The SRB treats this as a graded resolvability capability that has to be demonstrated on a continuous basis. Communication is one of the seven resolvability dimensions in the SRB’s Expectations for Banks (EfB), where it sits as dimension 6, and the guidance reads across to the EBA Guidelines on improving resolvability (EBA/GL/2023/05). Banks under the SRB’s direct remit for which resolution is the expected path are expected to meet the full set of these expectations by 30 April 2028, and to submit their communication plan to the SRB by April 2028.

The binding obligations sit in the SRMR, the Bank Recovery and Resolution Directive (BRRD) and the Market Abuse Regulation (MAR); the guidance carries no independent legal force. What the SRB has done is convert its expectations into an operational specification detailed enough to test against, drawing directly on the 2023 bank failures and the speed at which social media and instant payments can turn a rumour into a deposit run.

Related reading: the SRB’s operational guidance on liquidity and funding in resolution.

The calendar the build runs against

The picking reason for this topic is a deadline that sits roughly eighteen months out, so start with the dates that anchor the work:

• 17 October to 12 December 2025: public consultation on the draft communication guidance, with a technical meeting on 19 November 2025.
• 17 September 2026: the SRB publishes the Operational Guidance for Banks on Communication in Resolution and the Communication Testing Supplement. The manuscript was completed in July 2026.
• 30 April 2028: banks under the SRB’s remit are expected to meet the full set of expectations set out in the guidance. In specific cases, other transitional arrangements may apply, for example to switch banks and newly authorised banks.
• By April 2028: the communication plan is expected to be updated and submitted to the SRB, in line with the same compliance timeline.
• After April 2028: the plan is expected to be updated only where there are material changes (significant governance, business or corporate actions), where testing reveals gaps, or where the guidance itself is revised. Keeping contact details and other factual information current remains a continuous responsibility.

April 2028 is an SRB implementation horizon rather than a statutory remittance date: the SRB states that banks have until April 2028 to reflect the operational considerations, where needed, in their communication plans. Resolvability capabilities are also assessed through the SRB’s resolution-planning and testing framework.

Where the legal hook actually sits

Article 8(9)(n) SRMR is the anchor. It requires a communication plan to be prepared already in the context of resolution planning, which is why the SRB frames communication as a capability to be demonstrated on a continuous basis rather than assembled once a crisis is under way. The 2020 Expectations for Banks set two principles for the dimension: banks are expected to have a complete communication plan informing relevant stakeholders of the implications of resolution, with the aim of limiting contagion and avoiding uncertainty; and to have governance arrangements that ensure effective execution in close coordination with the SRB and the National Resolution Authorities (NRAs).

The SRB’s 17 September 2026 publication provides additional operational clarity on the Communication dimension of the Expectations for Banks, while the accompanying testing supplement defines testing areas and sub-areas, testing methods, and expectations for testing governance, design, preparation and reporting. Six overarching principles run through it: coordination and alignment with the authorities; strategic, stakeholder-centred planning; timeliness and sequencing; preparedness and operational capability; risk awareness and market confidence; and testing with continuous improvement. Each is applied in a manner proportionate to a bank’s size, structure and complexity, informed by dialogue with the Internal Resolution Team (IRT).

Reading the FSB material the SRB cites is worth ten minutes before drafting anything. The Financial Stability Board’s Key Attributes of Effective Resolution Regimes has carried communication expectations since 2011, and the SRB leans on the FSB’s post-2023 findings that fast payment technology and social media can accelerate a run and compress the runway to resolution. That is the reasoning behind the emphasis on versatile, responsive plans, and it lines up with the FSB’s cross-sectoral resolution planning work that RRD has covered separately.

Who has to build a plan, and who can lean on the parent

Scope follows Article 7 SRMR: the guidance applies to banks under the SRB’s direct remit, including significant entities or groups and other cross-border groups, where resolution is the expected strategy. For resolvability testing, however, the SRB states that it may place certain liquidation institutions under the testing framework in line with paragraph 26 of the EBA Guidelines on resolvability testing.

The common assumption that every legal entity in a group needs its own stand-alone plan is where teams get this wrong. For banking groups established outside the Banking Union with subsidiaries under the SRB’s remit, described in the guidance as hosted banks, a stand-alone communication plan is not expected where the subsidiary’s role and responsibilities for communication are clearly and sufficiently captured in the parent entity’s plan. The parent’s plan then has to cover the hosted dimension in a proportionate way: identifying the local critical stakeholders and their key messages, setting out how and when local authorities are contacted, allocating responsibility for communications with the hosted bank’s depositors and bondholders, and providing the governance to operationalise the plan locally. Only where those elements are absent or too thin does the hosted bank need to document them in a stand-alone plan.

Proportionality is applied through the IRT dialogue, case by case. A single-jurisdiction bank is expected to produce a simpler plan with limited stakeholder segmentation; a bank operating across several jurisdictions has to layer centralised and local messaging, handle jurisdiction-specific disclosures, and manage multilingual coordination. There is a strategy-specific carve-out worth flagging early: where the Sale of Business share deal is the preferred or variant resolution strategy, in principle there is no expectation that the plan covers the post-resolution phase, because the purchaser manages it.

The resolution communication plan across three phases

The plan is expected to cover all phases of a crisis with the focus on resolution, and the guidance is precise about where recovery-plan communication stops and resolution communication starts. Ahead of resolution, the bank runs the communication and disclosure plan attached to its recovery plan; resolution-related external communication is not foreseen in this phase, but the bank is expected to be ready to act if the crisis intensifies toward a failing-or-likely-to-fail (FOLTF) determination.

Once a bank is determined FOLTF, and until the resolution decision is publicly communicated, the plan addresses resolution-specific circumstances that go beyond the recovery-plan playbook and is activated as part of resolution governance. In principle the bank should not communicate to the media or the public about any potential resolution action during this window. The exception is communication needed to implement a moratorium under Article 33a BRRD, or the write-down or conversion of relevant capital instruments and eligible liabilities under Article 59(1)(a) BRRD. This phase closes on the SRB’s publication that the bank has been placed in resolution and the NRA’s press release on the national implementing act, and any resolution-related communication from the bank is expected to follow those announcements.

The post-resolution phase covers stabilisation. Where the open bank bail-in tool is used, the plan is expected to address communication tied to the business reorganisation plan, and RRD’s note on the SRB’s business reorganisation plan analysis report guidance is a useful companion here. A useful discipline is to avoid rebuilding from scratch: the guidance expressly allows a bank to reuse and cross-reference existing crisis and recovery documents, the bail-in playbook and the BRP analysis report, provided those deliverables meet the standards the communication guidance sets.

Critical stakeholders: the regulatory floor and the additions that matter

The plan has to identify and keep updated a list of the bank’s critical internal and external stakeholders, and the regulatory floor is set by Article 22(6) of Commission Delegated Regulation (EU) 2016/1075, which specifies the minimum set of critical stakeholder groups for resolution plans. The SRB treats that list as a starting point, not a ceiling, and expects enough granularity to build a targeted strategy for each group: an objective, a named process owner and key personnel, contact details, the channels to be used, the key messages, and a chronological timeline of steps before, during and after resolution.

The additions beyond the delegated-regulation baseline are where the plan earns its keep. Depending on the bank, they can include financial market infrastructures such as central counterparties and central securities depositories, credit rating agencies, deposit guarantee schemes, central banks, supervisory and governmental authorities (including in third countries), auditors and providers of critical technological services, and the press and media. Rating agencies deserve specific attention under an open bank bail-in: the guidance expects the bank to identify what information agencies need to regain or maintain a public rating and market access, and to build a process for supplying it, particularly where the entity has an issuer or issuance rating and is a Key Liquidity Entity expected to play a funding role after resolution.

For each critical stakeholder group the plan also separates the function that drafts the message from the function that disseminates it, where those differ, and it is expected to minimise the number of communications reaching a stakeholder from different sources across the group. For a Multiple Point of Entry group in particular, overlapping stakeholders across resolution groups are the norm, which is why group-level coordination is written into the plan explicitly.

Disclosure and MAR: silence is not the automatic default

Where a bank in resolution is an issuer within the scope of Article 17 MAR, its applicable market-disclosure obligations continue to apply. Preparatory steps toward resolution may qualify as inside information under Article 7 MAR, so the plan has to address the applicable disclosure and confidentiality mechanisms rather than assume disclosure obligations are suspended.

The guidance identifies three routes. First, Article 17(1) MAR, as amended by Regulation (EU) 2024/2809, provides that inside information relating to qualifying intermediate steps in a protracted process need not be disclosed; only the final circumstances or final event must be disclosed. Article 17(7) is the separate confidentiality-loss rule: if confidentiality is no longer ensured, the information must be disclosed as soon as possible. For preparation for resolution action, Commission Delegated Regulation (EU) 2026/789 identifies the resolution authority’s decision to take resolution action as the final event and the Article 83(4) BRRD publication as the disclosure point. Second, delayed disclosure under Article 17(4) or (5) MAR, where the conditions are met. Third, Article 84b BRRD provides for a resolution-authority confidentiality power, but Member States are required to transpose Directive (EU) 2026/806 by 11 May 2028 and apply those measures from 12 May 2028; before then, availability of such a power depends on applicable national law.

Confidentiality is the mirror image. Banks are expected to describe how they preserve the confidentiality of inside information relating to resolution. The plan should distinguish current MAR and national-law arrangements from the Article 84b BRRD power introduced by Directive (EU) 2026/806, for which Member States are to apply transposition measures from 12 May 2028. Where a bank chooses to handle this in another deliverable, such as the bail-in playbook or the BRP analysis report, that deliverable still has to meet the standards of the communication guidance. This is the section most likely to expose a gap between what a communications team assumes it can say and what securities law and the resolution authority actually permit, which is exactly why the guidance wants it mapped in advance instead of argued in the moment.

Moratorium messaging: the depositor-facing edge

A moratorium is the one place where the bank may have to communicate externally before the resolution announcement, so the guidance treats it separately. Under the BRRD, moratorium powers can be used at two stages: after a FOLTF determination and before the resolution decision under Article 33a BRRD, or when a resolution action is taken under Articles 69, 70 and 71 BRRD. Article 33a(11) BRRD bars the authority from exercising the in-resolution moratorium powers under Articles 69(1), 70(1) and 71(1) BRRD in respect of an institution after having applied the pre-resolution moratorium under Article 33a(1).

Operationally, if a moratorium is adopted the bank is expected to liaise closely with the SRB and the relevant NRA on media relations and on communications to customers, counterparties and secured creditors, and in particular covered depositors. It needs the governance, infrastructure, pre-defined messages and templates to manage a surge of queries, and the capability to explain the terms of the moratorium clearly: its scope, its effects on the legal relationships concerned, and its duration. The customer-facing communications are expected once the SRB and NRA publish the acts adopting the suspensions or restrictions. Getting the covered-depositor message right, fast and consistent with the deposit-guarantee position is the practical test here. Directive (EU) 2026/804 has amended the DGSD, but Member States must adopt and publish the implementing measures by 11 May 2028; most of those measures apply from that date, with specified provisions applying from 11 May 2029.

Governance, spokespeople and the infrastructure behind the message

The plan is only as good as the governance that fires it. Banks are expected to build arrangements for adapting the plan when material stress crystallises, with specific triggers set at a level that gives high confidence the update can be completed in both slow-moving and fast-moving scenarios. Staff, including contractors, are expected to know their roles and to be trained to the criticality of those roles, and testing exercises can count toward that training. Staff consultation during a resolution process, taking account of national systems for social dialogue, is anchored in Article 8(9)(m) SRMR.

Sign-off arrangements, cross-jurisdiction execution and monitoring all have to be documented, and two operational points stand out. Infrastructure has to be mobilisable at speed, including a call centre with surge capacity and hotlines for resolution-specific queries, plus systems to monitor and react to media. And the plan has to work outside office hours: the guidance explicitly contemplates a mid-week FOLTF declaration and expects processes for reaching internal and external stakeholders in extremely short timeframes and outside regular working hours. For a Multiple Point of Entry group the operating parent is expected to provide group-wide oversight, and where securities trade across time zones the arrangements have to synchronise the messaging.

On spokespeople, the guidance expects individuals with genuine public-speaking and media experience who are trained in the resolution framework and know their own bank’s strategy, and it asks for succession arrangements so the function survives a spokesperson being unavailable on the day. Resources named in the plan run from designated teams and appointed spokespersons to public-relations firms, Q&A libraries and a website ready to carry resolution-related information.

Managing the informational environment: monitoring and misinformation

The 2023 failures put social media at the centre of the guidance, and the informational-environment section is the most forward-leaning part of the document. Banks are expected to monitor both traditional and non-traditional channels for information on their financial position, and the guidance treats advanced tools, including AI-based solutions, as important for effective monitoring and timely detection of irregularities, with particular focus and resources on social media and the spread of misinformation before, during and after resolution.

Beyond monitoring, banks are expected to be able to respond quickly to misinformation across multiple channels, allaying unfounded fears with evidence-based narratives and coordinating with the authorities where needed, while also being able to address the fallout from leaks. The governance is expected to include a methodology for prioritising incidents involving leaks or misinformation, mapping them to the right mitigation strategy and to the point at which senior management is pulled in. This is where the communication capability becomes an operating function that has to be staffed and rehearsed.

Testing the capability: the Evidence Book and IRIS

The Communication Testing Supplement complements the SRB’s Operational Guidance on Resolvability Testing for Banks of 26 September 2025, adding a communication section that the consultation version did not contain. Communication capabilities are tested as part of the multi-annual testing programmes the IRTs set, across three testing sub-areas: management of the information and communication environments; adaptation of the communication plan to a specific stress and resolution scenario; and execution and monitoring of the plan across jurisdictions. No dedicated testing environment is required, no fixed reference date is prescribed (it is agreed with the IRT), and the SRB suggests bundling communication tests with tests on other dimensions to keep them realistic.

Two deliverables define what a test produces. For adaptation tests, the bank delivers a communication plan adapted to the scenario, in clean and tracked-change versions against the plan built in resolution planning, submitted to the IRT through the SRB’s IRIS platform. For execution tests, the bank compiles an Evidence Book on communication, a single organised file instead of a scatter of documents, containing the material foreseen for execution (messages to stakeholders, Q&A documents, press releases), the log of approvals, evidence of how infrastructure and resources were mobilised (including social-listening captures), monitoring evidence, and, for management simulations, summary notes of the senior-management sessions. The outcome report, and any independent observer report, is submitted via IRIS within one month of the test being finalised, unless the IRT agrees otherwise.

Frequently Asked Questions

Does this guidance create a new binding reporting obligation?

No. The guidance states it is not intended to create any legally binding effect and does not substitute EU or national law. The binding hook is Article 8(9)(n) SRMR, which requires a communication plan to be prepared in resolution planning; the disclosure, moratorium and confidentiality obligations sit in MAR and the BRRD. The guidance is the SRB’s specification of how it expects those obligations to be met and how it will assess resolvability, which is why it can still drive a substantial build even without binding force.

Our group is headquartered outside the Banking Union but has a subsidiary under the SRB’s remit. Do we need a separate plan?

Not necessarily. As a hosted bank you can rely on the parent entity’s plan, provided it clearly and sufficiently captures the hosted dimension, including local critical stakeholders and their key messages, how and when local authorities are contacted, responsibility for communications with local depositors and bondholders, and the governance to operationalise it. If those elements are missing or too thin, the subsidiary is expected to document them in a stand-alone plan.

Can we reuse our recovery plan, bail-in playbook or BRP analysis report instead of writing everything again?

Yes. The guidance expressly allows cross-referencing existing crisis, recovery and resolution deliverables to avoid duplication. The condition is that any document used to satisfy a requirement, whether for confidentiality, stakeholder coverage or execution, meets the standards set out in the communication guidance. A cross-reference that points to a weaker document does not discharge the expectation.

In a real event, who communicates first, the bank or the SRB?

Public communication on the resolution scheme is handled by the SRB and the relevant NRAs to keep the key messages consistent. The bank remains responsible for its own communications to shareholders, creditors and market participants, closely coordinated with the authorities, and it generally should not communicate about a potential resolution action before the SRB’s publication and the NRA’s press release, after which its resolution-related messaging follows.

If a residual entity survives a Sale of Business, does it keep communicating?

A material residual entity continuing to operate after a Sale of Business, for example under a transitional service agreement with the purchaser, is expected to coordinate its communication strategy with the strategy set by the SRB and the relevant NRA and to execute in line with the NRA, so that internal and external messaging stays consistent with the resolution objectives.

How does a moratorium change what we can tell depositors?

A moratorium under Article 33a BRRD is one of the situations in which the SRB guidance expects banks to be prepared for external communication before the resolution announcement. Once the SRB and NRA publish the acts adopting the suspensions or restrictions, the bank is expected to send tailored communications to affected stakeholders, in particular covered depositors, explaining the scope and duration of the moratorium clearly, and to adjust its disclosure plans for any obligations the moratorium triggers under securities law.

What counts as evidence that our communication capability actually works?

In a test, the Evidence Book on communication is the artefact: stakeholder messages, Q&A documents and press releases, approval logs, proof that infrastructure and resources were mobilised (including social-listening captures), monitoring evidence, and summary notes of senior-management sessions for management simulations. It goes to the IRT through IRIS, with the outcome report following within one month of the test being finalised.

Related Articles

• SRB Operational Guidance on Liquidity and Funding in Resolution: the sister operational guidance on liquidity and funding capabilities banks must demonstrate for resolvability.
• SRB Business Reorganisation Plan Analysis Report Guidance: how the BRP analysis report works after an open bank bail-in, a deliverable the communication plan cross-references.
• MREL Reporting Requirements: the loss-absorbing capacity reporting that underpins whether a resolution strategy is credible in the first place.
• SRB 2025 Annual Report: Resolution and Crisis Readiness: the SRB’s own reading of where banks stand on resolvability and crisis preparedness.
• CMDI Reform: Official Journal Publication: the crisis management and deposit insurance changes reshaping the resolution and depositor-protection perimeter.

Key Takeaways

• Banks under the SRB’s remit are expected to meet the full set of communication expectations by 30 April 2028 and to submit their communication plan to the SRB by April 2028, updating it thereafter only on material change or where testing reveals gaps.
• The binding hook is Article 8(9)(n) SRMR (a communication plan in resolution planning); the MAR and BRRD obligations behind it carry binding legal force; the guidance is an SRB operational specification without independent legal effect.
• The plan covers three phases (pre-resolution, in resolution, post-resolution); where a Sale of Business share deal is the strategy, the post-resolution phase is in principle not expected.
• The critical-stakeholder list starts from Article 22(6) of Commission Delegated Regulation (EU) 2016/1075 and extends to FMIs, credit rating agencies, deposit guarantee schemes, authorities and media as relevant.
• For issuers within MAR’s scope, Article 17(1) governs non-disclosure of qualifying intermediate steps in a protracted process, Article 17(7) requires disclosure if confidentiality is no longer ensured, and Article 17(4) or (5) may permit delayed disclosure where the relevant conditions are met. Article 84b BRRD introduces a resolution-authority confidentiality mechanism for which Member States are to apply transposition measures from 12 May 2028.
• For an Article 33a BRRD moratorium, the SRB guidance expects banks to be prepared for clear, fast messaging to affected stakeholders, particularly covered depositors, on scope and duration once the relevant adopting acts are published.
• Testing produces an Evidence Book on communication delivered via the SRB’s IRIS platform, with the outcome report due within one month of the test being finalised.

Sources and References

• Single Resolution Board, Operational Guidance for Banks on Communication in Resolution, September 2026: srb.europa.eu
• Single Resolution Board, Public consultation on the Operational Guidance on Banks’ Communication (launched 17 October 2025): srb.europa.eu
• Single Resolution Board, Operational guidance landing page (including the resolvability testing communication supplement): srb.europa.eu
• Single Resolution Board, Operational guidance on resolvability testing for banks, 26 September 2025: srb.europa.eu
• Single Resolution Board, Expectations for Banks, 10 April 2020: srb.europa.eu
• Single Resolution Board, Operational guidance for banks on resolvability self-assessment, 7 August 2025: srb.europa.eu
• European Banking Authority, Guidelines for institutions and resolution authorities on improving resolvability, EBA/GL/2023/05 (13 June 2023): eba.europa.eu
• Regulation (EU) No 806/2014 (Single Resolution Mechanism Regulation): eur-lex.europa.eu
• Directive 2014/59/EU (Bank Recovery and Resolution Directive): eur-lex.europa.eu
• Commission Delegated Regulation (EU) 2016/1075: eur-lex.europa.eu
• Regulation (EU) No 596/2014 (Market Abuse Regulation), as amended by Regulation (EU) 2024/2809: eur-lex.europa.eu
• Commission Delegated Regulation (EU) 2026/789 on disclosure of inside information in protracted processes and delay of disclosure: eur-lex.europa.eu
• Directive (EU) 2026/804 amending the Deposit Guarantee Schemes Directive: eur-lex.europa.eu
• Directive (EU) 2026/806 (CMDI reform directive, amending BRRD inter alia to insert Article 84b): eur-lex.europa.eu
• Financial Stability Board, Key Attributes of Effective Resolution Regimes for Financial Institutions (revised 25 April 2024): fsb.org

What to put on the resolution planning agenda next

The most useful first move is a mapping exercise: line up the guidance’s expectations against what already exists in the recovery plan, the bail-in playbook and the BRP analysis report, and mark where a cross-reference genuinely meets the standard and where a gap has to be filled. From there, the IRT dialogue sets proportionality, the stakeholder list is built out from the Article 22(6) baseline, and the disclosure and moratorium mechanics are pinned down with legal and the securities-law function before they are ever needed. The SRB states that banks have until April 2028 to reflect the operational considerations, where needed, in their communication plans. For testing, the outcome report is due via IRIS within one month of finalisation of the test unless otherwise agreed with the IRT.

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.