Resolution Reporting Requirements

The document defines resolution reporting and notification duties for financial institutions in Luxembourg—specifically those under:

The Single Resolution Board (SRB), responsible for cross-border and systemically relevant entities supervised by the ECB.
The CSSF itself, which oversees entities not covered by the SRB.

Key reporting types include:

SRB Reporting T (Liability Data, Critical Function, Financial Markets Infrastructure, Additional Liability Reports).
EBA Reporting Z, MREL & TLAC Reporting, and Impracticability Notifications—required under both SRB and CSSF oversight.

By January each year, the CSSF informs entities of their specific reporting obligations for the upcoming resolution cycle.

Reporting T (Annual, by 31 March / 30 April, depending on the report):
- Liability Data Report (LDR): covers groups with significant exposure or critical functions.
- Critical Function Report (CFR): identifies high-impact functions across geographies; due 30 April.
- FMIR: details on financial market infrastructure; annual, due 30 April.
- Additional Liability Report (ALR): temporary data on MREL/TLAC, as relevant.
EBA Reporting Z: annual submission by 30 April covering standard templates.
MREL & TLAC Reporting: quarterly reporting, due in February, May, August, and November, respectively.
Impracticability Notification: required when it is legally impracticable to include contractual bail-in recognition terms—submitted via XBRL, quarterly or semi-annually as applicable.

EBA Reporting Z: annual, with simplified templates potentially applicable for smaller or simpler institutions; due by 30 April.
MREL & TLAC Reporting: aligned with SRB timing—quarterly submissions with sign-off and checklists, but exemptions may apply.
Impracticability Reports: same expectations as SRB-remit entities for XBRL submission and timing.

Reference Date: All reports (T, Z, MREL/TLAC, impracticability) use data as of 31 December—regardless of entity’s financial year-end.
Currency Reporting:
- SRB-remit: exclusively in EUR.
- CSSF-remit: in the entity’s capital currency.
Filing Formats & Standards:
- XBRL is the required format for most submissions.
- ALR and management sign-off documents are delivered in Excel and PDF.
Taxonomies & Versions: Use EBA V3.5 and SRB V9.0.3 (both effective December 2024) for 2025 reports; older versions are not acceptable.
Validation Levels:
- Level 1: XBRL format compliance.
- Level 2: Business rule consistency.
- Level 3: Guidance adherence (e.g., LDR, CFR, FMIR guidelines).
File Naming & Transmission:
- Strict naming conventions must be followed.
- Files are transmitted to CSSF via secure “COF” channels; TEST and PRODUCTION environments exist, with specific codes for versions.
Resubmissions:
- Preliminary submissions are acceptable, but audited revisions must be submitted promptly when available.
- Resubmission of historical data is required if errors affect previous periods (1 year for annual, or 4 quarters for quarterly).

Check latest guidance and taxonomies before filing. SRB maintains up-to-date downloadable documents; CSSF does not define separate structures.
Insolvency Ranking: Always use the latest published ranking annex (for 2025, updated August 2024) when reporting.
Support Contacts:
- SRB-remit: via SRB Q&A portal or CSSF agent in the Internal Resolution Team (IRT).
- CSSF-remit: contact the assigned CSSF agent.
- Technical issues: gfd@cssf.lu / francois.basso@cssf.lu