What the Liability Data Report is
A resolution plan is only as good as the liability structure it is built on. Before an authority can decide which creditors would absorb losses, it needs to know exactly what the bank owes, to whom, under which governing law, with what residual maturity and with what ranking in insolvency. Published accounts do not answer those questions: they report liabilities by accounting category, not by their treatment in resolution.
The Liability Data Report was the instrument the Single Resolution Board built to close that gap, first collected in 2016. It broke the balance sheet down by insolvency ranking, by counterparty type, by residual maturity, by governing law and by issuing entity, and it identified own funds and eligible liabilities instrument by instrument — which is what allows an authority to test whether an instrument really meets the eligibility conditions of the CRR rather than trusting the issuer’s own classification.
What changed in 2026
The template is gone; the data is not. Commission Implementing Regulation (EU) 2025/2303 of 14 November 2025, published in the Official Journal on 10 December 2025, repealed Implementing Regulation (EU) 2018/1624 and reorganised resolution planning reporting into two harmonised returns:
- RESOL 1 — organisation and liability data, remitted by 31 March 2026 for the reference date of 31 December 2025.
- RESOL 2 — critical functions, relevant services and financial market infrastructures, remitted by 30 April 2026.
For banks under the SRB’s remit the practical consequence is that four separate collections disappear at once: the Liability Data Report, the Critical Functions Report, the Financial Market Infrastructure Report and the CIR template are no longer collected, and their content is redistributed across the harmonised templates. Submissions are made exclusively in XBRL-CSV under the EBA’s 4.2 reporting framework, so a spreadsheet that used to be emailed to a national authority is now a structured instance that has to pass validation before it is accepted.
Two SRB-specific collections survive alongside the harmonised return: the Additional Liability Report, requested case by case where RESOL 1 does not give enough detail — typically for multiple point of entry groups — and the Minimum Bail-in Data Template, which is not a planning return at all but the dataset a bank must be able to produce at short notice for a bail-in to be executed.
Where liability data lives now
Within RESOL 1, liability data is carried by two blocks of templates. The aggregate block describes the balance sheet in buckets; the granular block describes it transaction by transaction and, for securities, instrument by instrument. Every granular row reconciles back to a row and a column of Z 02.00, which is what makes the two views one dataset rather than two.
- Z 11.00Intragroup Liabilities, excluding Derivatives
- Z 12.00Securities (Including CET1, AT1 & Tier 2 Instruments; Excluding intragroup)
- Z 13.00All Deposits (excluding intragroup)
- Z 14.00Other financial Liabilities (not included in other tabs, excluding intragroup)
- Z 15.00Derivatives
- Z 16.00Secured Finance, excluding intragroup
- Z 17.00Other Non-Financial (not included in other tabs, excluding intragroup)
The instrument-level template, Z 12.00, is the one that overlaps with what this site publishes: it asks for the ISIN, the seniority claimed in the national creditor hierarchy, the governing law, whether a third-country law instrument carries a contractual recognition clause, the outstanding amount and the maturity — the same attributes the instruments database compiles from public sources, reported confidentially and in far greater depth.
Who files what
The implementing regulation differentiates by the role an entity plays in the resolution strategy. Resolution entities, entities earmarked for liquidation and the other entities of a resolution group do not report the same set of templates, and thresholds determine which subsidiaries count as relevant legal entities and therefore appear individually rather than only in the consolidated figures. The flag that carries this through the return is column 0320 of Z 01.01.
Institutions that benefit from simplified obligations report less, and the frequency and detail of what they do report is set by their authority. Where a data point has already been reported for the same reference date and scope in COREP, FINREP or IFREP, the framework is built to avoid collecting it twice — consistency with those returns is one of the first things validation looks at.
How the authority uses it
Three uses dominate. First, calibration: MREL is set as a percentage of the total risk exposure amount and of the leverage exposure, both of which arrive through Z 03.01, while the eligibility and maturity of the stack come from Z 02.00 and Z 12.00. Second, the bail-in itself: the aggregate liability structure is what a write-down and conversion would be applied to, ranking by ranking, which is why the exclusions of Article 44(2) BRRD have dedicated rows. Third, resolvability: governing law, contractual recognition, intragroup connections and counterparty concentration are read as impediments, not as descriptive detail.
The report is also why resolution authorities can speak about a bank’s bail-inable stack with precision that no public source matches. It is confidential; nothing on this site is drawn from it.