Why the concept exists
Liquidity in resolution is managed where the cash actually sits. A group-level forecast is of little use to a resolution authority if the funding needs arise in a subsidiary that cannot be reached by the parent's liquidity, or in a branch operating under a different currency and market infrastructure. Identifying the entities that matter for liquidity is therefore a precondition for the capability the Single Resolution Board expects of banks: to estimate liquidity needs in resolution, to measure and report the liquidity position at short notice, and to identify and mobilise collateral.
Key liquidity entities are the units where that exercise has to be performed in its own right.
How entities are identified
The assessment is specific to each group. It starts from the entities that are material to the resolution strategy, but it is not limited to them: a branch or a special purpose vehicle may be a key liquidity entity because of the funding it raises, the currency it operates in, the payment or settlement access it holds, or the intragroup flows that depend on it. Conversely, an entity that is material for other purposes is not automatically a key liquidity entity — the SRB expects the classification to reflect the entity's actual liquidity role, the structure of the resolution group and the bank's business model.
Alongside the entities themselves, banks identify key liquidity drivers: the exposures and behavioural flows that would move the liquidity position most sharply in a resolution scenario.
What banks are expected to do
For each key liquidity entity a bank should be able to produce a liquidity position and a short-horizon forecast on demand, in the relevant currencies, together with a view of the collateral available and the operational steps needed to mobilise it. The reporting is expected to work under crisis conditions and timelines, not only as a periodic exercise.
Status of the guidance
The SRB set out its expectations on liquidity and funding in resolution in operational guidance first published in 2021. In May 2026 the SRB opened a public consultation on a consolidated and updated version, which among other changes broadens the definition of key liquidity entities beyond material legal entities to any entity critical to group liquidity, including branches and special purpose vehicles. Banks should treat the consolidated guidance as work in progress until the SRB publishes the final text.