Questions and answers
The questions reporting teams ask about the transition from the Liability Data Report to RESOL 1 and RESOL 2: what changed, who files what, how the templates fit together, and what the SRB still collects separately.
Does the Liability Data Report still exist?
Not as a template. Since the reference date of 31 December 2025 the SRB no longer collects the LDR, the Critical Functions Report, the FMI Report or the CIR template; their content moved into the harmonised RESOL 1 and RESOL 2 templates. The name survives as shorthand for the liability data part of RESOL 1, which is why this section keeps using it.
What is the legal basis now?
Commission Implementing Regulation (EU) 2025/2303 of 14 November 2025, published in the Official Journal on 10 December 2025, which repealed Implementing Regulation (EU) 2018/1624. The templates and instructions are the annexes to that regulation, delivered through the EBA’s 4.2 reporting framework.
When is it due?
For the 31 December 2025 reference date, RESOL 1 is remitted by 31 March 2026 and RESOL 2 by 30 April 2026. MREL and TLAC reporting continues quarterly on its own ITS. See the calendar.
Who has to report, and does everyone report everything?
No. Requirements are differentiated by the role an entity plays in the resolution strategy — resolution entity, liquidation entity, or another member of a resolution group — and thresholds decide which subsidiaries are relevant legal entities reported individually. Institutions with simplified obligations report a reduced set on the terms their authority sets.
What does XBRL-CSV change in practice?
The return stops being a workbook and becomes a data point model instance subject to common validation rules. It has to pass validation before it is accepted, which moves a whole class of errors from the authority’s review to your own pipeline — and makes reporting a data engineering exercise as much as a regulatory one.
How do the granular tables relate to Z 02.00?
They are the same liabilities seen twice. Z 02.00 is the aggregate view by resolution treatment, counterparty and maturity; Z 11.00 to Z 17.00 describe each transaction, and for securities each instrument. Every granular row carries reconciliation columns pointing at the Z 02.00 row and column it belongs to.
Where do derivatives go?
Always in Z 15.00, one row per netting set, including when the counterparty is a group entity — the one carve-out from the rule that intragroup liabilities belong in Z 11.00. Only netting sets that are a net mark-to-market liability are in scope. In the aggregate view, rows 0330 to 0334 of Z 02.00 report derivatives on four different bases.
Which template carries instrument-level data with ISINs?
Z 12.00, which covers issued securities excluding intragroup — including own funds instruments — with the ISIN, the insolvency ranking claimed, the governing law, contractual recognition of bail-in where the law is third-country, amounts, coupon and dates. It is the closest thing in the return to what the public instruments database shows.
Does the SRB still collect anything outside the harmonised templates?
Yes. The Additional Liability Report is requested case by case, mainly for multiple point of entry groups, and the Minimum Bail-in Data Template is a readiness dataset a bank must be able to produce at short notice rather than an annual return. The SRB also continues to publish its annex on national insolvency ranking, which is what the ranking fields are reported against.
What happens if a submission fails validation or contains an error?
A file that fails validation is not accepted. Errors found after acceptance are handled by resubmission under the policy of the national resolution authority you file to: the harmonisation covers the templates, not the submission channel, the file naming or the resubmission triggers. Confirm those locally before the cycle starts.
Is this data ever published?
No. Resolution reporting is confidential. Nothing on this site comes from it — the instrument data published here is built from public registers, primarily ESMA FIRDS, as described in the methodology.