How to file, step by step

The steps below describe the process the implementing regulation and its instructions imply. They are a reference for people who already work in reporting, not a substitute for the legal texts or for your authority’s instructions.

1. Step 1

   Scope the entities before touching a number

   A closed list of legal entities and branches, each with a stable code.

   Everything downstream joins on the entity register in Z 01.01, so the submission is built from it outwards. Take the accounting scope of consolidation at the reference date, add resolution entities that sit outside it, and decide for each entity whether it is a resolution entity, a liquidation entity or another member of the resolution group — the differentiation the implementing regulation applies runs off that distinction.

   Then apply the thresholds that determine which subsidiaries are relevant legal entities. That flag, column 0320, decides which entities appear individually in the RESOL 2 templates instead of being folded into consolidated figures. Getting it wrong is expensive: it changes the population of half the return.

   Before you move on

   • —Every entity has an LEI, or the ECB MFI identifier used in RIAD where no LEI exists.
   • —The same code is used for the same entity in every template, including the granular tables.
   • —Branches are attributed to the country where they provide services, not where they are booked.
2. Step 2

   Fix the reference date and freeze the source systems

   One dated extract per source system, reconciled to the published balance sheet.

   Every figure describes the group as it stood on 2025-12-31. Residual maturity is measured from that date, not from origination, and the maturity ladders in Z 02.00 — one month, one year, two years, over two years — are computed against it.

   The one deliberate exception is the total SREP capital requirement in Z 03.01, which is reported from the latest official SREP decision communicated before the remittance date rather than from the position at the reference date.

   Before you move on

   • —Total liabilities across Z 02.00 tie to the audited or management balance sheet at the reference date.
   • —The extract is frozen: late corrections to a source system after the reconciliation is signed off are a resubmission, not an edit.
3. Step 3

   Classify liabilities by resolution treatment, not by product

   Each liability assigned to a Z 02.00 row and a counterparty column.

   This is the step where most of the work sits, and where accounting categories stop being useful. Z 02.00 splits liabilities into those excluded from bail-in under Article 44(2) BRRD (rows 0100 to 0210) and those that are not (rows 0300 onwards), and the test is legal. A deposit is not a single thing: the covered part is excluded, the uncovered but preferential part sits in row 0310, the uncovered non-preferential part in row 0320, each with its own maturity ladder. A secured liability splits too — the collateralised part is excluded under row 0120, the uncollateralised excess belongs in row 0340.

   Ranking is national. The order of the rows follows the creditor hierarchy as transposed in the Member State of the issuing entity, which is why the SRB publishes an annex on insolvency ranking for the reporting year and why a group operating in several jurisdictions cannot classify centrally without a legal mapping per country.

   Derivatives are reported on four bases in rows 0330 to 0334: after netting sets before collateral, after collateral, after collateral including estimated close-out amounts, and under prudential netting rules. Row 0333 is the definition every other template points at when it asks for a derivative amount.

   Before you move on

   • —Each counterparty column follows the FINREP sector classification; connected clients carry no sector.
   • —Outstanding amount and carrying amount are reported as a pair, and the difference between them is explainable.
   • —Instruments issued under third-country law are identified now — they are needed again in Z 12.00.
4. Step 4

   Build the granular tables from the same source, once

   Transaction-level and instrument-level rows that add up to the aggregate view.

   Z 11.00 to Z 17.00 describe the same liabilities again, at the granularity of the transaction — and for securities, of the instrument. The division between them is exclusive, and the instructions say so explicitly: intragroup exposures go in Z 11.00 and nowhere else, except derivatives, which always go in Z 15.00 whoever the counterparty is. Deposits go in Z 13.00, secured finance in Z 16.00, non-financial liabilities in Z 17.00, and Z 14.00 catches what none of the others take.

   Z 12.00 is the instrument-level table: ISIN, instrument type, governing law, contractual recognition of bail-in where that law is third-country, currency, outstanding principal, accrued interest, coupon, issue and maturity dates, and the insolvency ranking claimed. It also carries own funds instruments, with CET1 reported as the residual claim of shares on total accounting equity.

   Before you move on

   • —Derivatives are reported by netting set, one row per set, and only where the set is a net mark-to-market liability.
   • —Secured finance reports the liability, not the collateral.
   • —Where a creditor identifier is genuinely unavailable, the row is aggregated on that field rather than left blank.
5. Step 5

   Reconcile the granular tables back to Z 02.00

   Every granular row pointing at the aggregate cell it belongs to.

   Each granular table carries two reconciliation columns — 0020 for the Z 02.00 row and 0030 for the Z 02.00 column — and they are not decoration. They are what lets the authority add the detail back up and compare it with the aggregate view, and they are among the first things validation tests.

   Reconcile in both directions. A granular row pointing at a row of Z 02.00 that was reported as zero is an error in one of the two places, and finding out which one after the remittance date is the expensive path.

   Before you move on

   • —Sum of granular rows per (row, column) pair equals the Z 02.00 cell, within the tolerance your authority applies.
   • —Covered deposits in Z 06.00 agree with row 0110 of Z 02.00 for the same entity.
   • —Intragroup amounts in Z 04.00 and Z 11.00 tell the same story from both sides.
6. Step 6

   Run the RESOL 2 chain in the right order

   Functions, services and FMI dependencies mapped consistently.

   RESOL 2 is a chain of identifiers, and filling it out of order guarantees rework. The criticality assessment in the five Z 07.01 templates is reported once per Member State and produces the function identifiers; Z 07.02 maps those functions to legal entities and Z 07.03 lists core business lines with their own identifiers; Z 07.04 joins the two. Z 08.01 assigns a service identifier that Z 08.02 to Z 08.05 all reuse. Z 09.01 assigns the user/FMI/system-type/ intermediary combination that Z 09.02 to Z 09.04 reuse.

   Several of these templates declare a primary key made of specific columns. Duplicate keys are the most common structural rejection in this block, and they usually come from filling a mapping template from a spreadsheet that had one row per contract instead of one row per mapped relationship.

   Before you move on

   • —Only functions assessed as critical appear in Z 07.04 and Z 08.04.
   • —Only FMIs assessed as critical or essential appear in Z 09.02.
   • —Identifiers are stable across the whole block — and across next year's submission, if you want comparability.
7. Step 7

   Validate twice: EBA rules, then the authority's own checks

   A file that passes before it is sent, not after it is rejected.

   The return is a data point model instance subject to common validation rules, so a large share of errors is mechanically detectable before submission. Run the EBA validation rules of the reporting framework release you are filing under, then the additional checks your authority applies — the SRB publishes its Level 3 data quality checks as a spreadsheet of rules, updated during the cycle.

   Treat a passed validation as a floor, not a ceiling. Rules test internal consistency; they cannot tell you that a liability was classified into the wrong insolvency ranking, and that is precisely the error that changes the resolution plan.

   Before you move on

   • —Cross-template rules pass, not only within-template ones.
   • —Consistency with COREP, FINREP or IFREP for data points already reported there.
   • —Blank versus zero is deliberate everywhere: a cell that does not apply is left empty, a cell that is genuinely nil is reported as nil.
8. Step 8

   Submit in XBRL-CSV through the national channel

   An accepted instance, with the acknowledgement filed.

   For banking union groups the submission goes to the national resolution authority, which forwards it to the SRB; the SRB collects RESOL 1 and RESOL 2 from national authorities exclusively in XBRL-CSV. The remittance dates for the current cycle are 31 March 2026 for RESOL 1 and 30 April 2026 for RESOL 2.

   National authorities set their own submission channel, file naming and resubmission policy on top of the harmonised framework. Check theirs before the last week: the harmonisation is in the templates, not in the plumbing.

   Before you move on

   • —The instance validates against the taxonomy version in force for the reference date.
   • —Resubmission policy is known in advance — what triggers one, and by when.
9. Step 9

   Close the loop after submission

   A documented trail from source system to reported cell.

   Two things make next year cheaper. First, documented lineage: for every reported cell, which system it came from, which rule mapped it, and who approved the judgement calls — the classification of a liability into an insolvency ranking is a judgement, and it will be questioned. Second, the reconciliation pack, kept as evidence rather than rebuilt each cycle.

   Expect follow-up. The Additional Liability Report is requested case by case where RESOL 1 leaves a gap, and the Minimum Bail-in Data Template is a readiness obligation on a different timescale altogether: it has to be producible at short notice, which is a capability question, not a reporting one.