
EU SRB Consultation Timeline: EU Banks Face New Resolvability Testing Requirements
What Happened
Expectations for Banks [5.2] Consultation on SRB expectations on valuation capabilities Expectations for Banks [7] Consultation on SRB expectations on separability and operationalisation of transfer strategies Expectations for Banks [6] Consultation on SRB expectations on Communication in resolution Expectations for Banks [general] Consultation on the resolvability self-assessment template Expectations for Banks [general] Consultation on SRB expectations on bank resolvability testing 1 Guidance on scope : i) open/voluntary – open to all stakeholders, e.g. public consultations; or on a voluntary basis (e.g. as part of a right to be heard processes) ii) all – concerns all banking groups under the SRB’s remit ; iii) resolution groups – all banking groups under the SRB’s remit, which are earmarked for resolution (both SPE and MPE); iv) limited – a sub-set of banks under the SRB’s remit, e.g. all banks with a bail-in resolution strategy. Please note that all aforementioned definitions might encompass subsidiaries reporting on an individual basis, so e.g. “resolution groups” will also cover some subsidiaries, in line with specific instructions from IRTs or relevant accompanying reports. 2 Resolvability testing includes dry-runs, desktop exercises and walkthroughs when performed by banks. EBA MREL-TLAC report MREL quarterly monitoring Additional Liability Reporting Sign-off form on MREL eligibility of reported liabilities Self-assessment template on eligible liabilities Expectations for Banks [4.2] Results of Digital Operational Resilience Tests and information on preparatory measures for DORA Expectations for Banks [4.1] Additional OCIR information Expectations for Banks [7.1-7.3] Solvent Wind Down plans Expectations for Banks [7.1-7.3] Solvent Wind Down playbooks Expectations for Banks [3.2, 3.3] Joint Liquidity Template: bank-led testing deliverables Expectations for Banks [1.4, 5.3, 7.2] Expectations for Banks [2.3] Expectations for Banks [2.3] MBDT pilot dry-runs reports Expectations for banks [4] Access to FMIs: bank-led testing deliverables Expectations for Banks [4.6] FMI contingency plans Expectations for Banks [6.1] Expectations for Banks [7.2] Separability Analysis Report Expectations for Banks [7.3] Business Reorganisation Plan analysis reports Expectations for Banks [general] Resolvability work programme for 2026 Expectations for Banks [general] 2025 Resolvability self-assessment report Resolution Planning Reporting Liability Data Report Resolution Planning Reporting Critical Functions Report Resolution Planning Reporting Financial Market Infrastructures Reporting (FMIR) Resolution Planning Reporting EBA Resolution Reporting standard templates 3 While for other EfB’s dimensions banks may be requested to deliver a playbook or a report, since 2020, the way to provide such information on OCIR was left to IRT flexibility, which requested the information in different ways, such as by means of working technical notes, questionnaires, reports or playbooks. 4 The timeline has been moved from 31/12/2025 to 31/01/2026. 5 The timeline has been moved from 31/12/2025 to 31/01/2026. Single Resolution Fund Collection of data for SRF contributions calculation/ corrections of provided data for SRF The SRB levies fees on institutions, also known as contributions, to be paid into the Single Resolution Fund (SRF) in case the SRF target level 6 no longer meets a certain threshold prescribed by EU law. In order to calculate those contributions, when necessary, banks are required to report data to the SRB every year. Under EU law, banks can correct their data for the previous contribution cycles. The banks are required to report the corrected data to the SRB every year. Single Resolution Fund Consultation on (1) the preliminary amounts of contributions (only in case SRF contributions are collected in 2025) and (2) the preliminary settlements of differences due to restatements (when applicable). The SRB provides institutions with the possibilit
Practical Implications
Lawyers and compliance officers should note that the timeline for SRB consultations has been moved from December 31, 2025 to January 31, 2026, which may impact banks' reporting requirements and calculations of Single Resolution Fund contributions.
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