EBA Clarifies Z 08.02 Resolution Reporting Covers Applications Owned and Operated by Affiliated Prov

Key Takeaways

• The EBA has confirmed in a final Q&A that template Z 08.02 is reported once at group level and must include applications owned and operated by affiliated service providers when they underpin services supporting critical functions or core business lines.
• Reporting is not limited to assets the receiving entity owns or controls.
• Compliance and resolution planning teams should review their inventories and data collection processes to avoid gaps and duplicate reporting.

Deep Dive

The EBA has confirmed in a final Q&A that template Z 08.02 is reported once at group level and must include applications owned and operated by affiliated service providers when they underpin services supporting critical functions or core business lines. Reporting is not limited to assets the receiving entity owns or controls. Compliance and resolution planning teams should review their inventories and data collection processes to avoid gaps and duplicate reporting.

The key requirements are as follows. Under Article 3(1) of the ITS, Z 08.02 covers all group entities and is reported once at group level. The template therefore includes operational assets owned and operated by affiliated entities where they underpin services supporting the group's critical functions or core business lines. Each asset should be reported once at group level and linked to the relevant service as the template requires. Column 0070 (legal/contract type) must be completed from the perspective of the entity to which the intra-group or intra-entity service provider belongs. The Q&A sets no new deadlines. Note that it is non-binding guidance reflecting provisions in force on the publication date, and the EBA does not systematically update Q&As after legislative amendments.

Compliance teams, especially at subsidiaries of international banking groups, should take several steps:
- Confirm who is responsible for group-level Z 08.02 submissions and how data is sourced from affiliates.
- Reconcile application inventories against intra-group service catalogs to ensure affiliate-owned applications supporting critical functions are captured.
- Eliminate duplicate entries across entities so each asset is reported once.
- Map each asset to its service correctly.
- Review how column 0070 is populated, because the perspective rule may differ from current practice.
- Align Z 08.02 with the other service provider and inter-affiliate templates to keep reporting consistent.

The risks of misinterpretation include incomplete or inconsistent resolution reporting, supervisory findings, and weakened resolution authority visibility into operational continuity and critical dependencies. Institutions that had adopted the narrower entity-level approach may need to resubmit or restate prior data, depending on supervisory expectations. Impact is moderate to high for groups with extensive shared services, because data gathering, governance, and intra-group agreement documentation may need to be expanded. Teams should also monitor for further EBA or resolution authority communications.

Source: European Banking Authority