SRB Resolution Reporting: RESOL 1 and RESOL 2 Under the New ITS

ByRegReportingDesk

For the 2026 collection cycle, the Single Resolution Board is retiring the resolution templates that banks have filed for the best part of a decade. From this cycle, the SRB’s annual resolution-planning collection uses two reporting modules, RESOL 1 and RESOL 2, built on the revised Implementing Technical Standards in Commission Implementing Regulation (EU) 2025/2303. That Regulation was adopted on 14 November 2025, published in the Official Journal on 10 December 2025, and it repeals the previous ITS, Commission Implementing Regulation (EU) 2018/1624. The first data collected under it uses the reference date of 31 December 2025.

The practical effect lands squarely on reporting teams. The separate Liability Data Report, Critical Functions Report and Financial Market Infrastructure Report, together with the former CIR templates under Commission Implementing Regulation (EU) 2018/1624, are discontinued. The LDR, CFR, FMIR and CIR templates are replaced by the harmonised EBA 4.2 resolution templates, but not every former SRB data point moved into those Z-templates: for 2026 the remaining SRB-originated resolution-reporting requirement is the case-by-case Additional Liability Report for complementary MREL data. The SRB collects RESOL 1 and RESOL 2 from NRAs in XBRL-CSV and applies additional Level 3 data-quality checks; the SRB recommends that banks perform validation checks ensuring, among other things, reconciliation with FINREP and COREP where applicable. The SRB states that failure to comply with the resolution-reporting information requirements can be treated as an impediment to resolvability, potentially significant, and stresses both data quality and timely availability.

Related reading: MREL Reporting Requirements

The fixed calendar for a standard annual cycle runs as follows:

  • Reference date: the last day of the previous calendar year (31 December). For the 2026 cycle, that is 31 December 2025.
  • RESOL 1, organisation and liability data: due by 31 March.
  • RESOL 2, critical functions, relevant services and financial market infrastructure services: due by 30 April.
  • MREL and TLAC report: collected quarterly by the SRB.
  • Additional Liability Report: requested annually on a case-by-case basis at the same 31 December reference date.

Resolution reporting exists so that resolution authorities can draw up and keep current resolution plans and, where applicable, support the calibration of minimum requirements for own funds and eligible liabilities (MREL). The obligation to supply that information sits in the Bank Recovery and Resolution Directive, Directive 2014/59/EU, whose Article 11 covers the information institutions must provide for the purposes of resolution plans. The EBA drafted the standard forms and templates as an ITS, and the Commission adopted them as Commission Implementing Regulation (EU) 2025/2303. Within the Banking Union, the SRB centralises the collection for banks under its remit before that data is transferred to the EBA, acting under its own founding regulation, the Single Resolution Mechanism Regulation, Regulation (EU) 806/2014.

According to the SRB, the overhaul reduces the reporting burden on cross-border groups that were previously subject to both SRB and EBA resolution-planning obligations. The harmonised ITS dataset uses the EBA data point model and common validation rules, while the separate SRB Additional Liability Report remains an Excel collection. It also introduces differentiated reporting requirements depending on whether an entity is a resolution entity, a liquidation entity or an entity belonging to a resolution group, and it sets thresholds for identifying the legal entities that must be reported in detail. Those two design choices, differentiation by resolution strategy and materiality thresholds, are where most of the scoping work for a 2026 filing actually happens.

One point of confusion is worth settling early. The Regulation entered into force on the twentieth day after publication, on 30 December 2025. That in-force date marks when the standards begin to apply to the cycle reporting the 31 December 2025 position; the deadline for filing that position falls later and differs by report.

For institutions within the SRB’s remit, the SRB collects RESOL 1 and RESOL 2 from NRAs. At institution level, Article 6(2) of the ITS requires the relevant resolution authority to specify whether the information is submitted directly to the resolution authority or, where applicable, to the competent authority. Two distinctions inside that population decide how much each entity actually files, and they matter more than the headline scope.

For institutions that are not part of a group subject to consolidated supervision, Article 2 differentiates between resolution entities and liquidation entities that are not subject to simplified obligations. A standalone resolution entity reports all Annex I templates except Z 01.01, Z 04.00, Z 07.02, Z 07.03 and Z 11.00. A standalone liquidation entity without an Article 45(1) requirement determined under Article 45c(2a), second subparagraph, reports Z 01.02, Z 02.00, Z 05.01, Z 05.02, Z 06.00, Z 07.01.1 to Z 07.01.5, Z 07.04 and Z 09.01; where that requirement has been determined, Z 03.01 and Z 03.02 are added as applicable. Group reporting is governed separately by Articles 3 to 5.

The second distinction is the Article 1 definition of a ‘relevant legal entity’. A group entity other than a resolution entity, established in the Union, is relevant if any one of the Article 1 conditions is met: it provides critical functions; its individual total risk exposure amount, total exposure measure or operating income meets the applicable 2% threshold; its individual total assets exceed EUR 5 billion; or it is important for financial stability in at least one Member State. The tests are alternatives, but Articles 3 to 5 determine which templates and levels of application follow from that status. For a group comprising more than one resolution entity, Article 1 also modifies the denominator for the TREA and total-exposure tests to the applicable resolution-group consolidated level.

Third-country group members can appear in group reporting, but their treatment depends on the template. Article 1’s definition of a ‘relevant legal entity’ is limited to entities established in the Union, while Article 3(1) requires Z 01.01, Z 01.02 and Z 08.01 to Z 09.04 in relation to all group entities. Separately, the Additional Liability Report’s MPE reporting is by resolution group, including resolution groups located in the EU and in third countries; for a third-country resolution group, the guidance uses the applicable local capital requirement and, where relevant, MREL, TLAC or an equivalent resolution requirement. Reporting perimeters are drawn on the prudential or resolution scope of consolidation for the sub-consolidated views, while resolution groups themselves are defined by the Internal Resolution Teams together with the institution.

What the report contains: the RESOL 1 and RESOL 2 Z-templates

RESOL 1 carries organisation and liability data. It opens with the organisational-structure templates, Z 01.01 and Z 01.02, which map the group and its legal entities, and moves through the liability-side templates, Z 02.00 to Z 06.00, covering liability structure, own funds and eligible liabilities, intragroup financial interconnectedness, major counterparties and deposit-insurance information. Templates Z 03.01 and Z 03.02 report own-funds requirements for credit institutions and investment firms respectively; liability structure and MREL-eligibility data are captured in the liability templates, including Z 02.00 and, where applicable, the granular Z 11.00 to Z 17.00 templates. The revised ITS brings granular liability reporting into Z 11.00 to Z 17.00; these harmonised templates replace data previously collected through the SRB’s granular LDR framework.

RESOL 2 carries the operational-continuity side of a resolution plan. Its critical-functions templates include Z 07.01.1 for deposits, Z 07.01.2 for lending, Z 07.01.3 for payments, cash, settlement, clearing and custody, Z 07.01.4 for capital markets and Z 07.01.5 for wholesale funding; the Z 07 family also includes the mapping templates Z 07.02 to Z 07.04. The relevant-services templates, the Z 08 family, capture the services a resolution would need to keep running. The financial market infrastructure templates, the Z 09 family, record who provides FMI services to the bank and how they map to those critical functions: Z 09.01 lists FMI providers and users, Z 09.02 maps FMI services to critical functions, and Z 09.03 records key metrics such as default-fund contributions for central counterparties.

The liability templates record creditor hierarchy because ranking is relevant to the order in which claims bear losses, but bail-in scope is not determined by rank alone: liabilities excluded under Article 44 BRRD are outside the scope of the bail-in tool. In Z 02.00, aggregate liabilities are grouped into categories including liabilities excluded from bail-in and liabilities not excluded from bail-in, with rows including senior unsecured, senior non-preferred, subordinated and other MREL-eligible liabilities. The granular Z 11.00 to Z 17.00 templates separately record insolvency ranking, and several also capture amounts meeting MREL-eligibility conditions. The Annex on Insolvency Ranking sits behind this, mapping each national insolvency hierarchy so that the same liability is classified consistently across jurisdictions. Correct insolvency ranking is material to resolution analysis and to the assessment of liabilities and creditor hierarchy; an incorrect classification can therefore trigger data-quality queries or affect the resolution authority’s analysis.

The templates are interlinked, but there is no general one-to-one rule that every critical function in Z 07 must have a matching FMI entry in Z 09. Where an FMI is reported as critical in Z 09.02, the template identifies the country and critical-function ID by reference to Z 07.01; relevant-services mappings are handled separately in the Z 08 family. Apply the EBA taxonomy and validation rules to the relationships actually reported rather than creating FMI mappings solely because a function is marked critical.

Reference dates and deadlines: 31 March for RESOL 1, 30 April for RESOL 2

Resolution reporting under the ITS is annual, and the reference date is the last day of the previous calendar year. Article 6 of the Regulation sets two remittance dates against that reference. The organisational-structure, liability and own-funds templates, the RESOL 1 set, are due at the latest by 31 March each year in respect of the previous 31 December. The critical-functions, relevant-services and FMI templates, the RESOL 2 set, are due at the latest by 30 April each year in respect of the same reference date. In the 2026 cycle, that means RESOL 1 by 31 March 2026 and RESOL 2 by 30 April 2026, both reporting the 31 December 2025 position.

Those dates are the bank remittance deadlines for the standard ITS templates. Article 6 requires institutions, or Union parent undertakings for groups, to submit the RESOL 1 templates by 31 March and the RESOL 2 templates by 30 April for the previous calendar year-end, subject to the next-business-day rule. Resolution authorities specify whether submission is made directly to the resolution authority or, where applicable, to the competent authority.

The MREL and TLAC report runs on a different clock. The SRB collects it quarterly, in line with the EBA ITS on disclosure and reporting of MREL and TLAC, and uses it to set and monitor compliance with MREL targets. The Additional Liability Report is different again: it is requested annually on a case-by-case basis at the 31 December reference date. Where the SRB has not asked a given group for the Additional Liability Report, that report is simply not due.

Submission channel and format: XBRL-CSV through the NRA

RESOL 1 and RESOL 2 are collected by the SRB from the NRAs exclusively in XBRL-CSV. The format change is significant for teams that last built resolution files under the old framework: the earlier resolution returns were delivered as XBRL instances against the SRB’s own taxonomy packages, and the move to the framework 4.2 technical package changes both the taxonomy and the packaging. The SRB’s instruction is blunt: the EBA’s technical reporting standards on the EBA website should be followed to the letter to ensure the data validates on the way through the NRA and up to the EBA.

The Additional Liability Report breaks the format pattern deliberately. It is collected in Excel, and the SRB flags this explicitly. Its file-naming convention is prescribed in the guidance as IDI_Country_Filingtype_ReferenceDate.xlsx, where the identifier is the entity’s LEI, or its RIAD MFI code where no LEI exists, or a local identifier agreed with the NRA, the country is the ISO 3166-1 alpha-2 code of incorporation, the filing type is the literal string AddLiabReport, and the reference date is written YYYY-MM-DD. All amounts in the Additional Liability Report are reported in EUR units.

For RESOL 1 and RESOL 2, the SRB collects the reports from NRAs; the relevant resolution authority specifies the institution-level submission route under Article 6(2) of the ITS. For MREL and TLAC reporting questions, the SRB directs institutions to the EBA or the responsible NRA.

Validation rules and SRB data-quality checks

The 2026 reporting package combines EBA framework validation rules with SRB Level 3 data-quality checks. The first is the common EBA validation-rules layer that comes with the single data point model in framework 4.2, applied uniformly across the standard. The second is the SRB’s own set of additional checks, referred to as Level 3 checks, published as the SRB Level 3 data quality checks version 2.1, last updated on 1 April 2026, with the rule logic expressed in Groovy. The SRB strongly encourages reporting entities to run these Level 3 checks before submitting to the NRA, and expects banks to have taken all necessary steps by the deadline to ensure compliance with the checks.

The SRB publishes additional Level 3 data-quality checks for the 2026 resolution collection and strongly encourages reporting entities to apply them before submitting data to NRAs. The SRB may update the list and may run additional checks on a case-by-case basis.

Above the SRB’s own logic sits reconciliation with the bank’s other regulatory reports. The SRB recommends that banks perform validation checks ensuring, among other things, reconciliation with FINREP and COREP where applicable, which means a liability or exposure figure that does not tie back to the corresponding FINREP or COREP line may be identified by those reconciliation checks. If resubmission is needed after the deadline, the SRB accepts it in line with the applicable EBA guidelines, so a late correction follows a defined path.

Caveats and interactions: proportionality, discontinued templates and overlapping reports

Proportionality is delivered through several mechanisms. The ITS differentiates the template set by reporting-entity type and relevant-legal-entity status, while simplified information obligations may also be laid down by the resolution authority under Article 4 BRRD. The revised ITS expressly preserves those simplified obligations and allows the resolution authority to request additional information from entities subject to them where necessary for resolution planning.

The discontinuation of the old returns carries a documentation consequence that is easy to miss. Because the Liability Data Report, Critical Functions Report, FMI Report and the CIR templates under Commission Implementing Regulation (EU) 2018/1624 are being replaced, the SRB is no longer updating or publishing the guidance documents that went with them. The one exception the SRB has kept is the Annex on Insolvency Ranking. The live 2026 Resolution Reporting page has since been rolled forward to a 2027-labelled annex, so that later file should not be treated as evidence of the annex version applicable to the March/April 2026 collection; use the cycle-specific version communicated for the 2026 collection. A team that still reaches for the old LDR or CFR guidance will not find a current version, and should map its data against the EBA framework 4.2 instructions instead.

The resolution return overlaps with the quarterly MREL and TLAC report under Commission Implementing Regulation (EU) 2021/763 and with the Additional Liability Report. For supervisory reporting, the current ITS is Commission Implementing Regulation (EU) 2024/3117, as amended, which repeals Commission Implementing Regulation (EU) 2021/451 subject to transitional provisions under Article 25 of that Regulation. That deliberate non-duplication is why the Additional Liability Report is narrow and conditional: its MPE tab is filled only by groups under a multiple-point-of-entry strategy, its mortgage-credit-institution tab only where the deconsolidation under Article 45a(2) of the BRRD applies, and its other-data tab only where a figure needed at the MREL scope is not already reported in the resolution or supervisory returns. Reading the Additional Liability Report as a general top-up return, when it is only a gap-filler for those specific situations, over-scopes the work.

Recent and upcoming changes: the 2026 transition and what follows

The anchor change is the 2026 cycle itself. It is the first collection under Commission Implementing Regulation (EU) 2025/2303 and EBA reporting framework 4.2, reporting the 31 December 2025 reference date, and it is the cycle in which the LDR, CFR, FMIR and older creditor-information templates stop being collected. The supporting artefacts moved with it: the 2026 Additional Liability Report was updated to version 1.1. The SRB states that, compared with ALR 2025 and ALR 2026 version 1.0, version 1.1 adds a new tab for one data point previously reported in the LDR: Total Assets. The SRB Level 3 checks are listed as version 2.1, last updated on 1 April 2026. The live 2026 Resolution Reporting page has since rolled its insolvency-ranking link forward to a 2027-labelled annex, which should not be treated as the 2026-cycle annex without a cycle-specific source.

For teams that report other EBA frameworks alongside resolution data, the version cadence is worth tracking, because resolution reporting now sits inside the same framework-release machinery as prudential reporting, no longer on a separate SRB-only track. The SRB has also signalled that it retains the flexibility to request additional information whenever it considers it necessary, so the fixed annual and quarterly returns are a floor the SRB can add to for a given resolution group.

Frequently Asked Questions

If a bank filed the old LDR, CFR and FMIR last year, does the same data simply move into RESOL 1 and RESOL 2?

The old LDR, CFR, FMIR and CIR templates are discontinued and replaced by the harmonised ITS templates. The 2026 build should therefore be mapped directly to the applicable framework 4.2 templates and instructions rather than copied from the former returns. For the SRB collection from NRAs, RESOL 1 and RESOL 2 are collected in XBRL-CSV.

Which deadline binds a bank, the 31 March and 30 April dates in the ITS or an earlier NRA date?

The ITS itself sets the bank remittance dates: 31 March for the RESOL 1 templates and 30 April for the RESOL 2 templates, each for the previous calendar year-end. The relevant resolution authority specifies the submission route. Any institution-specific operational cut-off communicated by the authority should be tracked separately, but the ITS does not create a generally earlier NRA deadline.

Is the Additional Liability Report always required?

No. The SRB requests it annually on a case-by-case basis, and its tabs are conditional: the MPE tab applies only to groups under a multiple-point-of-entry strategy, the mortgage-credit-institution tab only where deconsolidation under Article 45a(2) of the BRRD applies, and the other-data tab only where a figure needed to set MREL is not already reported in the resolution or supervisory returns. A group that receives no request, and that has no gap to fill, does not file it.

Does the resolution submission need to agree with FINREP and COREP?

The SRB recommends that banks perform validation checks ensuring, among other things, reconciliation with FINREP and COREP where applicable; its Level 3 checks are the additional data-quality checks used for the 2026 collection. A liability or exposure figure that does not reconcile to the corresponding supervisory line is a predictable trigger for a data-quality query.

What happens if a submission fails a Level 3 check after the deadline?

The SRB strongly encourages reporting entities to apply the Level 3 checks before submitting data to NRAs and expects banks, by the reporting deadline, to have taken all necessary steps to ensure compliance with those checks. Where resubmission is needed, the SRB accepts it in line with the applicable EBA guidelines. The SRB states that failure to comply with the information requirements can be treated as an impediment to resolvability, potentially a significant one.

How are third-country entities in a resolution group treated?

Third-country entities can be included in group-level reporting, but the scope depends on the template. Article 1’s ‘relevant legal entity’ definition is limited to Union-established entities, while Article 3(1) requires Z 01.01, Z 01.02 and Z 08.01 to Z 09.04 in relation to all group entities; other templates follow their specific Article 3 scope rules. Separately, the Additional Liability Report’s MPE reporting covers resolution groups located in the EU and in third countries, and the guidance specifies local capital and, where relevant, MREL, TLAC or equivalent resolution requirements for third-country resolution groups, without phase-in.

Key Takeaways

  • From the 2026 cycle, SRB resolution reporting is RESOL 1 and RESOL 2 under Commission Implementing Regulation (EU) 2025/2303, which repealed CIR (EU) 2018/1624 and reports the 31 December 2025 reference date first.
  • RESOL 1 (organisation and liability data) is due by 31 March each year; RESOL 2 (critical functions, relevant services and FMIs) by 30 April; both against the previous 31 December.
  • The LDR, CFR, FMIR and former CIR templates are discontinued, and the corresponding SRB guidance is no longer maintained, except the Annex on Insolvency Ranking; use the cycle-specific annex communicated for the 2026 collection rather than treating the later 2027-labelled file now shown on the live page as the 2026-cycle version.
  • RESOL 1 and RESOL 2 are collected exclusively in XBRL-CSV via the NRA; the Additional Liability Report is collected in Excel with a prescribed IDI_Country_AddLiabReport_ReferenceDate.xlsx file name, all amounts in EUR.
  • A group entity other than a resolution entity, established in the Union, is a relevant legal entity if it meets any one of Article 1’s conditions, including providing critical functions, the applicable 2% TREA, total-exposure-measure or operating-income tests, total assets above EUR 5 billion, or financial-stability importance; Articles 3 to 5 then determine the templates and reporting level.
  • The SRB strongly encourages entities to apply its Level 3 checks (v2.1, 1 April 2026) before submission and expects banks, by the reporting deadline, to have taken all necessary steps to ensure compliance; the SRB recommends validation checks that ensure reconciliation with FINREP and COREP where applicable, and failure to comply with information requirements can be treated as an impediment to resolvability.
  • The Additional Liability Report is conditional and case-by-case, filling only gaps not covered by the resolution ITS, the MREL and TLAC ITS (Commission Implementing Regulation (EU) 2021/763, as amended) or the current supervisory reporting ITS (Commission Implementing Regulation (EU) 2024/3117, as amended).

Sources and References

Filing the 2026 resolution reporting cycle without surprises

The work that decides a clean 2026 filing happens before any template is opened: confirm each entity’s resolution or liquidation status, run the Article 1 thresholds to fix which legal entities report in detail, and rebuild the mapping from last year’s LDR, CFR and FMIR data into the RESOL 1 and RESOL 2 Z-templates instead of assuming a straight migration. Then hold two dates. Run the SRB Level 3 checks and, where applicable, reconcile the resolution data with FINREP and COREP against the 31 December 2025 position; then file the RESOL 1 templates by 31 March and the RESOL 2 templates by 30 April, following the submission route specified by the relevant resolution authority.

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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