Feedback statement on the public consultation on resolvability self-assessment.
Date: 2025-08-07
Institutions: Single Resolution Board
Subjects: bank, bank resolution, banking, banking policy, banking supervision, banking system, financial audit, financial intervention, financial risk, financial solvency, financial stability

FEEDBACK STATEMENT ON 
THE PUBLIC CONSULTATION  
ON RESOLVABILITY 
 SELF-ASSESSMENT

srb.europa.eu

This  publication  is  not  intended  to  create  any  legally  binding  effect  and  does  not  in  any  way 
substitute the legal requirements laid down in the relevant applicable European Union (EU) and 
national laws. It may not be relied upon for any legal purposes, does not establish any binding 
interpretation of EU or national laws and does not serve as, or substitute for, legal advice. 

The Operational guidance for banks on resolvability self-assessment is subject to further revisions, 
including due to changes in the applicable EU legislation. The SRB reserves the right to amend 
this publication without notice whenever it deems appropriate, and it shall not be considered as 
predetermining the position that the SRB may take in specific cases, where the circumstances of 
each case will also be considered.

Manuscript completed in July 2025

This  document  should  not  be  considered  as  representative  of  the  Single  Resolutions  Board’s 
official position.

Luxembourg: Publications Office of the European Union, 2025

© Single Resolutions Board, 2025

Reproduction is authorised provided the source is acknowledged.

For  any  use  or  reproduction  of  elements  that  are  not  owned  by  the  Single  Resolutions  Board, 
permission may need to be sought directly from the respective rightholders. The Single Resolutions 
Board does not own the copyright in relation to the following elements:

Cover: © Lobet - Rostovikova · PRYZM

Print 

ISBN 978-92-9475-428-8 

doi:10.2877/4534013 

FP-01-25-006-EN-C

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ISBN 978-92-9475-427-1 

doi:10.2877/7211932 

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FEEDBACK STATEMENT ON  
THE PUBLIC CONSULTATION  
ON RESOLVABILITY  
 SELF-ASSESSMENT

srb.europa.eu

2

Table of contents

1.  Introduction 

2.  Main remarks made in response to the 
consultation 

Format of the self-assessment 

Scope of the self-assessment 

Frequency of the self-assessment 

Granularity 

Advanced capabilities 

Variant strategies 

Market transparency 

Scenarios-based assessment 

Link to testing 

Resolvability capabilities 

Other comments 

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Single Resolution Board I Feedback statement on the public consultation on resolvability self-assessment3 

1.  Introduction

The  Single  Resolution  Board  (SRB)  consulted  stakeholders  on  the  Operational 
guidance  for  banks  on  resolvability  self-assessment  (the  guidance)  between  3 
December 2024 and 7 February 2025. The guidance is part of the SRM’s strategic 
review to ensure that European banks are equipped for the future and crisis-ready, 
based  on  a  revised  methodology  encompassing  lessons  learnt  from  crisis  cases, 
best practices and the testing of banks’ capabilities.

The SRB received 13 responses to the consultation paper from banking associations, 
banks  and  representatives  of  academia.  This  document  summarises  the  main 
comments raised in the public consultation and sets out how they have been addressed.

2.  Main remarks made 
in response to the 
consultation

Format of the self-assessment

Respondents  generally  considered 
is  adequate. 
that 
Notwithstanding,  respondents  suggested  that  the  self-assessment  template  be 
supplemented  with  a  separate  Word/PDF  document  or  additional  columns/tabs. 
This  suggestion  was  made  on  the  basis  that  the  template  in  its  existing  format 
might not be sufficient to capture all the necessary information. 

the  Excel 

format 

The  SRB  maintains  its  general  view  that  the  self-assessment  template  should  tie 
together  different  elements  of  crisis  readiness  and  reflect  the  bank’s  view  on  its 
own  resolvability.  It  should  not  be  a  duplication  or  aggregation  of  information 
provided  in  other  operational  documents/deliverables  expected  by  the  SRB.  As 
outlined  in  Annex  1  of  the  guidance,  the  executive  summary  should  be  used  by 
the  bank  to  describe  the  main  conclusions  of  the  self-assessment,  highlighting 
the most relevant findings and elements that, in the bank’s view, contribute to its 
crisis preparedness.

Respondents  proposed  to  report  information  requested  under  columns  ‘Test(s) 
performed’  and  ‘Accompanying  documents’  at  a  less  granular  level.  In  addition, 
several  respondents  requested  that  the  inclusion  of  the  ‘Measures  to  be  taken’ 
column be revisited, considering that similar information is provided in the annual 
Resolvability Work Programme.

Single Resolution Board I Feedback statement on the public consultation on resolvability self-assessment4

Based  on  this  feedback,  the  revised  guidance  now  clarifies  that  the  columns 
‘Reasoning’  and  ‘Measures  to  be  taken’  may  be  completed  by  cross-referencing 
supporting  documents  submitted  by  the  bank.  In  addition,  it  clarifies  that  the 
column on ‘Accompanying documents’ is optional depending on whether the bank 
chooses  to  provide  additional  supporting  documentation  (not  mentioned  in  the 
column  ‘Reasoning’)  to  justify  the  assessment.  Finally,  the  SRB  has  revisited  the 
reporting instructions related to the ‘Test(s) performed’ column where reporting is 
now requested at principle level, rather than at capability level. 

Scope of the self-assessment

Some  respondents  queried  whether  entities  with  a  liquidation  strategy  and  less 
significant  institutions  (LSIs)  are  in  scope  of  the  guidance.  As  already  clarified  in 
the Chapter 3.2 of the consultation document, the guidance applies only to banks 
under the SRB’s direct remit that are earmarked for resolution. It does not apply 
to  liquidation  entities1  or  directly  to  LSIs.  The  latter  should  follow  the  guidance 
received from the relevant national resolution authority.

Additional information on the scope, format and submission process was requested 
by  certain  respondents  for  cross-border  groups  and  for  banks  under  a  multiple 
point of entry (MPE) strategy. To address this, the revised guidance now includes 
an overview of the reporting requirements considering the complexity of the group 
structure and the link with the resolution strategy.

Some respondents suggested that a gradual phase-in, akin to that applied for the 
development of the Expectations for Banks (EfB), be applied for the self-assessment 
report for ‘switch banks’ and newly authorised banks. The SRB maintains its view that 
the self-assessment report should be completed by switch and newly authorised 
banks against all applicable principles. This will allow for the identification of the EfB 
areas that have not yet been met by the bank, and so as to facilitate prioritisation. 
Notwithstanding,  these  banks  will  only  be  requested  to  provide  a  justification  of 
their assessment regarding the capabilities that have been phased in. The guidance 
has been updated to reflect this clarification.

Two respondents suggested that non-resolution entities should not be included in 
the scope of the guidance on the grounds that most of the capabilities do not apply 
to  them.  The  purpose  of  the  self-assessment  report  is  to  assess  the  resolvability 
of the resolution group as whole hence also considering the roles played by non-
resolution entities in the overall resolution planning. This is in accordance with the 
European  Banking  Authority  (EBA)  Guidelines  on  improving  resolvability2  which 
highlight  the  importance  of  completing  the  resolvability  self-assessment  also  at 
the level of non-resolution entities, particularly outside of the home jurisdiction, in 
order to help ensure crisis readiness at the level of the whole group.

Several  other  respondents  enquired  about  the  role  of  non-resolution  entities  in 
preparing  the  self-assessment  report.  Chapter  3.4  of  the  consultation  document 
clarifies that to ensure the coherence of the resolvability assessment at the level 

1  As referred to in Article 2(1), point 83aa, of Directive (EU) 2014/59/EU.

2  EBA/GL/2022/01, as amended by EBA/GL/2023/05 (‘Guidelines amending Guidelines EBA/GL/2022/01 
on improving resolvability for institutions and resolution authorities under articles 15 and 16 of Directive 
2014/59/EU (Resolvability Guidelines) to introduce a new section on resolvability testing’).

Single Resolution Board I Feedback statement on the public consultation on resolvability self-assessment5 

of  the  resolution  group,  it  is  expected  that  the  resolution  entity  coordinates  the 
overall process and submits one resolvability self-assessment report on behalf of 
the resolution group to the SRB. Thus, the resolution entity may request that the 
necessary  assessments  be  performed  by  non-resolution  entities.  The  relevance 
of  the  capabilities  for  non-resolution  entities  are  bank-specific  and  should  be 
discussed with the corresponding internal resolution team (IRT). 

Frequency of the self-assessment

A number of respondents suggested reducing the reporting frequency of the self-
assessment report from once a  year,  to  once  every  two  years,  at  least  for banks 
which  already  meet  the  EfB  to  a  large  extent.  An  annual  submission  of  the  self-
assessment  report  ensures  that  the  IRT’s  annual  resolvability  assessment  of 
banks  and  setting  of  the  testing  programme  are  based  on  adequately  updated 
information.  However,  the  SRB  acknowledges  most  banks  have  reached  an 
advanced  stage  of  implementation  of  the  EfB.  The  SRB  has  therefore  revised 
its  approach  and  reporting  of  the  self-assessment  report  will  now  be  requested 
once every two years. Nevertheless, in line with the EBA Guidelines on improving 
resolvability,  where  necessary,  the  IRT  may  request  an  interim  self-assessment 
report and/ or additional underlying evidence in the areas where work is expected 
to be completed.

Some respondents suggested to apply an earlier or later submission date for the 
self-assessment report compared to the one provided in the consultation document 
(i.e.  by  31  January  at  the  latest).  The  SRB  maintains  its  view  that  the  proposed 
submission date ensures the continuity with the current approach, ensuring that 
self-assessments  are  provided  on  a  timely  basis  to  ensure  adequate  planning  of 
the testing exercises and prioritisation of bank deliverables as part of the overall 
resolution planning and resolvability assessment processes.

Granularity

Most  respondents  found  the  self-assessment  template  overly  granular  and 
suggested  reducing  the  number  of  capabilities  while  improving  differentiation 
between  capability  levels,  particularly  on  management  information  systems 
(MIS).  During  the  EfB  implementation  phase,  the  SRB  received  multiple  requests 
to disclose the capabilities used to conduct its resolvability assessment of banks. 
The self-assessment template has been developed in such a way as to satisfy this 
request, providing full transparency regarding the capabilities the SRB uses in its 
resolvability assessment methodology. However, following the comments received, 
the revised self-assessment template has been reviewed to reduce the granularity 
of the capabilities by 20 %. Additionally, the extent to which more differentiation 
could be introduced across capability levels has been assessed. The main changes 
and their rationale are discussed in the relevant sections of this document. 

Respondents emphasised the need for the self-assessment template to be tailored 
to  each  bank  to  ensure  proportionality.  Separately,  it  was  queried  whether  the 
differing levels of granularity of capabilities across resolvability dimensions would 
result  in  different  ‘weights’  assigned  to  capabilities  in  the  SRB  methodology.  As 
already clarified in the operational guidance, the self-assessment template should 

Single Resolution Board I Feedback statement on the public consultation on resolvability self-assessment6

be  tailored  to  each  bank.  IRTs,  in  collaboration  with  each  bank,  will  evaluate 
the  relevant  capabilities  and  the  extent  to  which  they  are  expected  to  be  met. 
Banks  will  also  be  informed  of  the  ‘impact’  each  EfB  principle  has  in  the  overall 
self-assessment exercise, determined on the basis of the resolution strategy and 
bank-specific characteristics.

Several respondents enquired about the application date of some new capabilities, 
emphasising the need for sufficient time to implement them gradually as part of a 
multi-year  work  programme.  The  self-assessment  template  incorporates  insights 
from new guidance the SRB intends to consult and publish in selected areas, such 
as valuation and communication. With this consultation, the SRB aimed to obtain 
early feedback on the guiding principles of these new guidance documents, which 
will undergo a more detailed consultation later this year. In these areas, the SRB will 
maintain a proportionate approach, ensuring gradual implementation that will be 
reflected in the annual priority letters for each bank. 

Respondents also sought clarification on how the capabilities outlined in the self-
assessment  template  align  with  the  EfB  and  the  EBA  Guidelines  on  improving 
resolvability. The self-assessment template reflects the EfB and the corresponding 
set of capabilities required for their implementation. It is therefore more granular, 
since  it  incorporates  the  operational  guidance  documents  published  over  the 
years across the key dimensions of the EfB as well as experience gained from the 
EfB  implementation  in  various  areas.  As  a  result,  the  self-assessment  template 
is  consistent  with  the  EfB,  which  in  turn,  are  aligned  with  the  EBA  Guidelines  on 
improving resolvability. 

Advanced capabilities

Most respondents are not in favour of including ‘advanced capabilities’ in the self-
assessment report, as they were regarded as ‘best practices’ going beyond the legal 
requirements and, in some cases, the scope of the EfB. Respondents were of the 
view they should not be requested to report their implementation status on these 
capabilities,  nor  should  they  trigger  any  remedial  actions,  such  as  adjustments 
to  minimum  requirement  for  own  funds  and  eligible  liabilities  (MREL)  or  the 
identification of substantive impediments. Respondents also raised concerns about 
their  relevance  and  proportionality  for  all  institutions,  particularly  for  smaller  or 
medium-sized banks, as well as whether they would be applied on a case-by-case 
basis.  Respondents  suggested  that  if  these  capabilities  were  retained  in  the  new 
methodology, they should be presented as ‘best practices’ for sharing insights on 
how banks have structured certain aspects of their resolution strategies, solely for 
informational purposes.

In the context of crisis preparedness, the SRB aims to further refine the principles 
for  assessing  banks’  resolvability,  ensuring  they  are  robust,  effective,  and  fit  for 
purpose.  To  this  end,  it  is  committed  to  implementing  the  EfB  as  efficiently  as 
possible, tailoring them to the specific characteristics of each bank and resolution 
strategy.  As  part  of  its  strategy  to  enhance  resolution  readiness,  the  SRB  has 
shared  examples  of  the  most  advanced  capabilities  adopted  by  certain  banks  to 
strengthen their resolvability. These advanced capabilities are intended to support 
the broader banking sector while maintaining a flexible approach, avoiding a rigid, 
‘one-size-fits-all’ model.

Single Resolution Board I Feedback statement on the public consultation on resolvability self-assessment7 

The SRB aims for an effective adoption of the bank-specific ‘advanced capabilities’ 
wherever  they  are  deemed  necessary  to  enhance  the  resolvability  of  the  bank. 
Before requesting banks to implement any advanced capabilities at the resolution 
planning  stage,  the  SRB  will  seek  to  ensure  that  they  are  both  necessary  and 
proportionate to support the resolvability of the banks concerned.

In  the  upcoming  resolution  cycle,  the  relevant  capabilities  will  be  set  on  a  bank-
specific basis by the IRT for monitoring purposes. Following the first cycle, the SRB 
will assess whether any bank-specific advanced capabilities should be included, e.g. 
in Level 3.

Variant strategies

Some  respondents  showed  a  preference  for  presenting  the  progress  on  the 
operationalisation  of  the  variant  resolution  strategy  (VRS)  in  a  single  column  of 
the  self-assessment  template  alongside  the  preferred  resolution  strategy  (PRS). 
Respondents highlighted that the VRS complements the PRS and that presenting 
them  together  in  a  single  column  would  provide  a  clearer  and  more  efficient 
overview of their overall resolvability status.

Other respondents argued that two separate columns would provide greater clarity 
and more accurately reflect the progress made on each strategy. These respondents 
pointed out that while the VRS is often developed in conjunction with the PRS, it 
still constitutes a distinct strategy, and the varying levels of progress between the 
two could justify separate columns. A distinction between the two strategies would 
enable better tracking of each strategy’s specific progress.

The SRB will design the representation of the progress on the operationalisation 
of  the  PRS  and  the  VRS  in  two  separate  assessments  within  the  self-assessment 
template.  This  will  allow  for  a  more  detailed  and  accurate  representation  of 
progress on each strategy and provide stakeholders with a clearer understanding 
of where each strategy stands.

Respondents  mainly  considered  the  capabilities  related  to  separability  and 
reorganisation, testing, and MIS relevant for the assessment of the VRS.

The SRB has taken this into account in finalising the structure of the self-assessment 
report and the future heatmap. 

Market transparency

Aggregated level

Benchmarking  the  results  of  resolvability  assessments  is  widely  regarded  as  an 
essential tool for fostering convergence among banks with similar business models 
and resolution strategies. The majority of respondents agreed that key dimensions 
such  as  business  model,  bank  size  and  country-related/regional  differences  are 
critical  for  drawing  meaningful  conclusions.  Additionally,  some  respondents 
suggested incorporating distinctions based on resolution strategy (e.g. single point 
of entry strategy vs MPE) to allow for more targeted benchmarking. 

Single Resolution Board I Feedback statement on the public consultation on resolvability self-assessment8

The  SRB  will  take  this  feedback  into  account  for  future  publications  of  the 
assessment of banks’ resolvability across the banking union. 

Individual level

Most  of  respondents  do  not  envisage  disclosing  individual  information  on  their 
resolvability progress and related activities and/or to make reference to potential 
authorities’ publications. The main concerns on doing so relate to potential unlevel 
playing  field  and  to  possible  misinterpretation  of  such  disclosures,  as  well  as 
pressure on the bank’s reputation.

The SRB will take this feedback into account in considering the future approach to 
individual data disclosure.

Scenarios-based assessment

Most  respondents  questioned  the  necessity  of  incorporating  scenario-based 
assessments in the resolvability self-assessment, arguing that the self-assessment 
is deemed to evaluate core capabilities applicable to any crisis and that the selection 
of resolution strategies (PRS and VRS) aims to address a wide range of scenarios. 
Additionally,  respondents  stressed  that  such  an  approach  would  unnecessarily 
complicate  the  process  and  increase  banks’  workload,  given  the  vast  array  of 
potential crisis events that could be considered. They emphasised that resolvability 
primarily depends on how effectively these capabilities are operationalised, which 
is  best  assessed  through  testing.  Furthermore,  respondents  noted  that  banks 
already account for various crisis scenarios in existing resolution planning activities, 
including  bail-in  playbooks,  business  reorganisation  plans  (BRP),  separability 
analysis reports and liquidity in resolution.

Since  banks  already  incorporate  scenario-based  analysis  into  their  regular 
resolution planning activities – an effort set to expand with the systematic testing 
of their resolvability capabilities under a multi-annual testing programme – banks 
will not be expected to complete the self-assessment under crisis scenarios.

Link to testing

Most  respondents  considered  the  self-assessment  template  adequate  to  identify 
the  areas  that  have  been  tested  and  to  be  tested.  However,  three  respondents 
noted that tests are usually conducted at a more aggregated level, that is, at the 
principle  or  dimension  level  of  the  EfB.  Additionally,  one  respondent  suggested 
that  references  to  planned  tests  should  be  limited  to  banks’  budgeted  work 
programmes  and  that  the  template  should  exclude  results  from  deep-dives  and 
on-site  inspections  conducted  by  resolution  authorities.  One  respondent  asked 
to  clarify  whether  testing  outcomes  should  be  reflected  in  the  self-assessment 
template and whether they should be assigned a certain ‘weight’.

Since testing exercises are usually conducted at a more aggregate level than the self-
assessment template, the template has been revised to reflect testing at the principle 
level of the EfB. The operational guidance already specifies that the self-assessment 
template  should  take  into  consideration  the  results  of  the  tests  conducted,  and 

Single Resolution Board I Feedback statement on the public consultation on resolvability self-assessment9 

serve as a basis for calibrating banks’ multi-annual testing programmes. As such, 
it is not intended to reflect future tests. The SRB confirms that the results should 
be considered in each bank's compliance assessment, although no specific weight 
is assigned to them. While deep dives and on-site inspections differ in nature from 
bank-led tests, any relevant findings from these exercises provide insights on the 
extent  to  which  the  bank  meets  every  resolvability  capability  and,  therefore,  are 
also expected to be incorporated into the self-assessment report.

Resolvability capabilities

Governance and testing

Respondents  proposed  changes  to  the  classification  of  capabilities  across 
levels  and  dimensions  to  avoid  overlap  and  to  ensure  better  calibration  of  the 
assessment.  Taking  these  suggested  changes  into  consideration,  the  SRB  has 
merged certain capabilities.

The  capability  relating  to  internal  control  systems  was  perceived  as  being  overly 
restrictive as it referenced a specific internal control model. The capability has now 
been reformulated to allow more flexibility for banks to introduce models of their 
choice as long as they provide adequate checks and balances.

One  respondent  asked  for  greater  clarity  on  the  use  of  terms  in  relation  to 
capabilities  to  demonstrate  active  involvement  of  management  body  and  senior 
management  (Principle  1.1)  to  ensure  that  they  are  understood  correctly.  The 
terminology used by the SRB is clarified in the glossary included at the end of the 
operational guidance.

One respondent has highlighted that testing environments should not be required 
by the SRB, unless it has been demonstrated that the capability cannot be tested 
without it. The wording of the capability has been modified accordingly to allow for 
sufficient flexibility.

Loss absorption and recapitalisation capacity

Overlaps across dimensions

Some  respondents  questioned  the  inclusion  of  capabilities  for  identifying  and 
classifying  bail-inable  liabilities  under  loss  absorbing  capacity  (Principle  2.1), 
suggesting  they  belong  under  MIS  (Principle  5.1)  or  bail-in  execution  (Principle 
2.3). The guidance has been amended to reflect the cross-cutting nature of bail-in 
operationalisation, covering governance, documentation, communication and MIS 
aspects.  The  SRB  retained  the  original  allocation  of  capabilities  across  principles 
but clarified definitions and questions raised on the goal of the capabilities. 

Calibration of capabilities

Regarding  bail-in  execution  (Principle  2.3),  some  respondents  argued  that  the 
scope of the bail-in playbook may be too broad and should account for differences 
in balance sheet structures to prevent unnecessary work beyond what is required 
to ensure resolvability. To further ensure proportionality, respondents advocated 

Single Resolution Board I Feedback statement on the public consultation on resolvability self-assessment10

for introducing materiality for the operationalisation of instruments issued under 
third-country law.

When defining core capabilities for Principle 2.3, the revised guidance focuses on 
the liabilities ensuring compliance with the MREL requirement and on addressing 
the  risk  of  breaching  the  ‘no  creditor  worse  off’  principle.  Therefore,  the  revised 
approach  will  factor  in  differences  in  balance-sheet  structures  and  other  bank-
specific features. Banks should continue work on operationalising bail-in for all bail-
inable liabilities, including beyond Level 3.

Scope of the bail-in playbook and discretionary exclusions

Some  respondents  asked  for  clarifications  of  certain  concepts  such  as  ‘material 
liabilities’. In addition, respondents argued that the operationalisation of bail-in for 
liabilities  which  are  likely  to  be  discretionarily  excluded  (as  well  as  those  ranking 
above MREL requirements) would be costly and inefficient.

The  SRB  notes  that  recital  70  of  the  Bank  Recovery  and  Resolution  Directive 
(BRRD) emphasises the need for the bail-in tool to be applicable to the broadest 
possible  range  of  unsecured  liabilities  to  ensure  its  effectiveness.  Additionally, 
recital 1 of Delegated Regulation (EEU) 2016/860 reinforces this objective, stating 
that no liabilities should be presumed exempt from bail-in unless explicitly listed 
under Article 44(3) BRRD. In resolution planning and when assessing resolvability, 
authorities should seek to minimise exclusions from bail-in to uphold the principle 
that shareholders and creditors bear the costs of resolution. Finally, it also follows 
from Article 27(5) of the Single Resolution Mechanism Regulation that discretionary 
exclusions can only be applied in exceptional circumstances and provided that the 
conditions set out therein are met.

Consequently,  the  SRB  is  not  in  a  position  to  exclude  certain  categories  of  bail-
inable  liabilities  from  the  scope  of  the  bail-in  playbook,  even  when  a  resolution 
plan identifies some liabilities as likely to be discretionarily excluded. Furthermore, 
any conclusion on an eventual discretionary exclusion rests with the SRB. The re-
calibration  of  bail-in  execution  (Principle  2.3)  discussed  above,  together  with  the 
approach taken on advanced capabilities, intends to increase proportionality in this 
area in terms of prioritisation of work to operationalise bail-in. As aforementioned, 
banks are expected to continue operationalising the full scope of bail-inable liabilities.

Cross-border recognition of resolution action

In order to support cross-border recognition of resolution action and compliance 
with  Articles  69  to  71a  BRRD,  banks  are  expected  to  amend  relevant  financial 
contracts governed by third-country law by adhering to available market standards 
(e.g. International Swaps and Derivatives Association Resolution Stay Protocols) or 
through other agreements.

Respondents argued that compliance with Article 69 to 71a BRRD depends on the 
counterparties’ adherence to market standards and resolution stay protocols, not 
on the adherence by the bank in resolution. Respondents also suggested clarifying 
that  only  financial  contracts  governed  by  third-country  law  that  create  a  liability 
should be considered relevant under this principle.

Single Resolution Board I Feedback statement on the public consultation on resolvability self-assessment11 

The  SRB  has  not  introduced  any  amendments.  Since  banks  have  limited  control 
regarding the adherence of counterparties to the standards, the principle focuses 
on  the  adherence  of  the  bank  itself  to  such  standards  –  which  is  considered  to 
be  a  pre-condition  for  reciprocity  by  the  relevant  counterparty.  Regarding  the 
requirements under Article 69 to 71a BRRD, relevant financial contracts may extend 
beyond those under which the bank has a payment or delivery obligation.

MREL-eligible liabilities issued under third-country law

In relation to the capability to demonstrate an understanding of how to support the 
process of obtaining a court ruling (advanced capability under Principle 2.2), one 
respondent requested clarification that this specific expectation is not applicable 
for banks whose MREL eligible liabilities under third-country law have been issued 
in  jurisdictions  where  recognition  is  not  obtained  through  judicial  means  and/or 
where a contractual recognition and a legal opinion confirming the enforceability of 
resolution clauses have already been secured. The SRB was also requested to explain 
the expectations behind this capability, with reference to the relevant guidance.

To address this, the wording of the capability has been modified. It now clarifies that 
demonstration is only of potential relevance in jurisdictions where legal recognition 
is achieved through judicial means and the amount issued under that third-country 
law is material (> 10 % of the MREL capacity). Regarding the legal opinion confirming 
the  enforceability  of  resolution  clauses,  banks  are  expected  to  engage  with  their 
non-EU counsels to: (i) assess whether the conditions for requesting a court ruling 
are met and, if so; (ii) describe the process and the expected timeline; (iii) identify 
the  necessary  documents  to  submit;  (iv)  outline  potential  issues  that  may  arise 
around  such  request,  and;  (v)  the  effect  of  the  court  ruling  on  the  execution  of 
the bail-in.

MREL

Respondents  raised  concerns  about  meeting  the  MREL  requirement  solely  with 
subordinated  instruments  (the  advanced  capability  under  Principles  2.4  &  2.5), 
arguing  that  this  might  negatively  affect  banks’  financial  flexibility  and  exercise 
cost pressure. In this context, the SRB would like to clarify that this capability does 
not  introduce  a  new  subordination  requirement  or  articulate  any  expectation 
that  banks  should  meet  the  MREL  requirement  exclusively  with  own  funds  or 
subordinated eligible liabilities. Rather, it seeks to recognise the fact that a larger 
layer  of  subordinated  instruments  facilitates  resolution.  The  capability  does  not 
create any new obligation for banks to increase current levels of subordination or 
even an expectation to increase subordination beyond the levels mandated under 
the MREL decision.

Respondents  also  asked  for  further  clarifications  in  relation  to  the  capabilities 
related to the monitoring of the concentration in retail holdings and contagion risk 
through  interbank  holdings  (the  advanced  capability  under  Principles  2.4  &  2.5). 
In particular, respondents identified difficulties in quantifying retail and interbank 
holdings  notably  due  to  secondary  market  transactions.  The  SRB  acknowledges 
the  challenge  involved  in  measuring  holdings  built  through  secondary  market 
purchases. To address this, the reporting of interbank holdings will only be expected 
from banks where specified by IRTs based on bank-specific risk profiles. Regarding 
the assessment of the concentration of retail holdings in the self-assessment, banks 

Single Resolution Board I Feedback statement on the public consultation on resolvability self-assessment12

are expected to consider the aggregate amounts of securities with a denomination 
below EUR 50 000 as a benchmark for the retail investor base3. 

Liquidity and funding in resolution

Several respondents provided comments and suggestions on capabilities related to 
liquidity and funding in resolution. Respondents remarked that certain capabilities 
appeared  to  go  beyond  the  resolvability  expectations  laid  down  in  the  SRB’s  EfB 
document.  For  example,  the  capability  whereby  banks  are  expected  to  report 
updated  daily  data  for  all  datapoints  in  a  standardised  format,  is  an  advanced 
capability and should be appreciated in accordance with the relevant explanation 
provided in the SRB Operational guidance. Respondents also suggested to reorder 
or  merge  some  capabilities/EfB  principles  to  improve  consistency  and  to  avoid 
some potential redundancies. On that point, it is important to emphasise that the 
three EfB principles relating to Liquidity and funding in resolution have laid down 
expectations that are complementary but that are different in terms of nature and 
contents. Thus, some parts related to collateral cannot be disentangled from the 
Principles 3.1 and 3.2. Notwithstanding, two capabilities related to the estimation 
of the liquidity needs at the moment of the failing-or-likely-to-fail declaration, and 
in all resolution phases, have been merged due to similar expectations. Similarly, 
two  Level  2  capabilities  related  to  the  provision  of  information  and  the  ability  to 
mobilise sources of collateral have also been merged.

Operational continuity in resolution (OCIR) and access to financial market infrastructure 

(FMI) services

In  respect  of  OCIR,  two  respondents  noted  potential  duplication  and  a  lack  of 
differentiation  across  levels  of  capabilities.  The  SRB  has  addressed  this  feedback 
by  updating  the  self-assessment  template  to  ensure  greater  distinction  between 
capabilities. Regarding the perceived lack of differentiation between levels, it should 
be noted that the capabilities have been developed in a progressive manner. For 
example, regarding risks to OCIR, at Level 2 the bank is expected to describe only 
a  preliminary  list  of  risks  while  at  Level  3  a  comprehensive  risk  assessment  is 
requested. Another example relates to the financial resilience of service providers, 
where  the  amount  of  liquidity  resources  to  be  segregated  by  banks  have  been 
graded by capability level. This means that banks are only requested to segregate 
20 % of annual fixed overheads in order to achieve the Level 3 capability, and 50 % 
so as to achieve the advanced capability.

Respondents  also  requested  clarifications  in  respect  of  certain  definitions  which 
the SRB has now updated. For example, further clarification has now been provided 
that digitalisation is linked to the Digital Operational Resilience Act (DORA), aligning 
with the explanation in the updated Operational guidance on OCIR. 

Three respondents provided feedback on the FMI-related capabilities. The feedback 
can be categorised into requests for clarification, and concerns on proportionality 
and feasibility of certain capabilities. On the requests for clarification, the SRB has 
provided  further  explanations  to  banks  to  ensure  a  consistent  implementation 
of  the  capabilities.  In  respect  of  respondents’  concerns  regarding  proportionality 

3  By reference to the option of Members States in paragraph 5 of Article 44a BRRD to set a minimum 
denomination amount of at least EUR 50 000 for the selling of subordinated eligible liabilities to retail 
clients.

Single Resolution Board I Feedback statement on the public consultation on resolvability self-assessment13 

and feasibility, the SRB has made the necessary adjustments to take the feedback 
into account where relevant. To this end, the SRB has revisited some capabilities, 
either  via  adjusted  wording  or  by  removing  certain  elements  from  the  template. 
In a similar vein, the SRB has re-classified certain capabilities to better reflect the 
advancement expected to operationalise the aforementioned capabilities.

Information systems and data requirements

Some  respondents  commented  on  perceived  duplication  between  the  different 
resolvability  conditions  and  the  MIS  dimension.  The  SRB  MIS  capabilities  focus 
on the automation of the information in respective areas, whereas the principles 
related  to  FMIs,  OCIR,  BRP  and  liquidity  focus  on  the  bank’s  ability  to  produce 
the  related  information,  whether  automated  or  not.  Therefore,  the  SRB  has  not 
changed the classification of MIS capabilities. 

MIS capabilities to produce the information for valuation

Some respondents noted that the capabilities do not provide sufficient differentiation 
across levels. As already communicated in the technical meeting with the industry, 
the MIS capabilities to produce the necessary information for valuation has been 
aligned  to  the  new  SRB  Expectations  on  Valuation  Capabilities,  which  is  planned 
to  be  published  at  the  end  of  2025.  The  capability  relating  to  banks’  ability  to 
produce information to support a valuation based on the scope defined by the IRT 
has remained the same. Capabilities on valuation playbooks and data repositories 
that were originally reflected as advanced capabilities have now been refined and 
moved  to  lower  levels  to  reflect  their  phase-in,  in  line  with  the  SRB  Expectations 
on Valuation Capabilities. Additionally, the capability relating to the valuation data 
index  has  been  included.  Instead,  the  advanced  level  now  reflects  the  ability  to 
produce the information necessary to ensure a fair, prudent and realistic valuation. 
Consequently, the comments raised concerning better differentiation between two 
levels has been addressed.

MIS  capabilities  to  produce  the  information  for  the  implementation  of  the 

resolution tools

Respondents  found  that  providing  the  information  for  all  bail-inable  liabilities  is 
unrealistic for large banks, given the level of losses that would need to be incurred 
to mobilise the entire scope of bail-inable liabilities. Additionally, one respondent 
noted  that  the  description  of  MIS  capabilities  should  not  form  part  of  the  bail-in 
playbook. 

Similarly  to  the  approach  followed  for  Principle  2.3,  the  scope  of  the  different 
principles  has  been  adjusted  to  reflect  the  likelihood  of  bail-in,  taking  MREL 
requirements  as  a  reference.  As  for  the  description  of  MIS  capabilities,  the  SRB 
notes that bail-in playbooks are internal documents of the banks, aimed at allowing 
the operationalisation of the tool. As such, the bank can structure the information 
in separate documents, as long as the combination of these documents meets the 
requirements of the Operational guidance on bail-in playbooks.

Single Resolution Board I Feedback statement on the public consultation on resolvability self-assessment14

Communication

Respondents noted that certain capabilities within this dimension appeared to go 
beyond the EfB and the SRB guidance documents, thus introducing detailed new 
requirements. Additionally, respondents generally found certain capabilities to be 
duplicative, redundant or too detailed. It is worth highlighting that this EfB dimension 
has  been  enhanced  on  two  fronts:  i)  compilation  of  communication-related 
expectations from the EfB and other SRB guidance documents, and ii) instillation 
of lessons learnt from recent banking crises. Hence, the majority of the capabilities 
are existing expectations that have been refined to ensure the comprehensiveness 
and operationalisation of the communication strategy deployment. Based on the 
feedback from the public consultation, certain modifications have been made to the 
capabilities to re-calibrate their proportionality (such as allowing discretion at the 
IRT level for defining the list of critical stakeholders and removing the expectation 
for a call centre to be functioning 24-hours).

Separability, transferability and restructuring 

Structure and complexity

Regarding  banks’  structure  and  complexity  (Principle  7.1),  respondents  found 
the  self-assessment  template  too  granular.  In  order  for  the  SRB  to  obtain  an 
understanding of banks’ complexity, it is necessary to conduct a detailed analysis. 
Therefore,  the  assessment  criteria  have  not  been  revised,  although  it  is  recalled 
that certain capabilities only apply to a subgroup of banks (e.g. those with an MPE 
strategy, cooperatives, those with international presence, etc.).

Separability and transferability analyses for transfer tools

As  regards  separability  (Principle  7.2),  several  respondents  suggested  that  the 
SRB provides further clarification of the information to be included in separability 
analysis  reports  and  transfer  playbooks.  The  SRB  is  currently  updating  the 
Operational guidance on separability for transfer tools, which is planned for public 
consultation in Q3 2025. This document will elaborate on common capabilities that 
institutions need to have in place to support resolution authorities in the application 
of  all  transfer  tools  as  well  as  specific  capabilities  that  are  more  tool-specific.  In 
parallel, the SRB intends to publish a transfer playbook guidance which will support 
banks in building their capabilities for operationalising the transfer process. 

Business reorganisation

Regarding  BRP  (Principle  7.3.1),  one  respondent  noted  that  some  concepts,  such 
as  the  maximum  reorganisation  capacity  (MRC),  are  not  legally  defined  and  are 
scenario  dependent,  which  they  argued  should  not  be  the  case  in  resolution 
planning.  However,  these  concepts  are  not  intended  as  additional  requirements 
but  rather  as  steps  to  operationalise  the  expectations.  The  core  bank  should 
remain stable while business lines may undergo reorganisation, since one of the 
pre-requisites  for  the  analysis  is  that  all  business  lines,  both  core  and  non-core, 
could be loss making in resolution. The selection of reorganisation measures and 
MRC quantification are innately scenario-dependent and are necessary in order to 
assess banks’ capabilities to conduct the analysis.

Single Resolution Board I Feedback statement on the public consultation on resolvability self-assessment15 

One  respondent  also  questioned  the  requirement  to  update  the  BRP  analysis 
report,  particularly  the  quantitative  information,  on  an  annual  basis.  An  annual 
update may be expected until full compliance is achieved or if significant changes 
occur in the bank’s activities.

Solvent wind-down (SWD) of trading books 

Regarding the SWD (Principle 7.3.2), respondents highlighted that the forecast of 
the  rump  portfolio  can  be  difficult  to  estimate  and  proposed  focusing  another 
capability  on  the  quantification  of  resources  needed  to  maintain  the  rump 
portfolio post-execution. Over the last three years of implementation, the SRB has 
observed that most banks that have been asked to submit SWD plans were able to 
produce this information forecast in a credible manner and detail the content of 
both the discretionary and structural rump at granular level (i.e. products/trades 
transactions).  The  capability  related  to  the  maintenance  of  the  rump  has  been 
slightly modified to encompass quantification of resources.

Other comments

Grading system

Two respondents suggested replacing the grading system with the following four 
categories: ‘High’, ‘Medium-High’, ‘Medium-Low’ and ‘Low’. Some respondents also 
suggested extending the four-point grading scale to a broader range of capabilities, 
noting that some still allowed only a binary response (‘Compliant’/‘Non-compliant’).

The SRB considers it essential to retain the ‘Compliant’ category to recognise banks 
that have fully implemented certain resolvability capabilities. The other proposed 
categories  are  already  reflected  within  the  SRB  grading  system  (e.g.  the  ‘Largely 
compliant’  grade  encompasses  banks  included  in  the  ‘High’  and  ‘Medium-High’ 
categories etc.). As a result, the SRB has not revised the grading system. The SRB 
also  assessed  the  capabilities  where  a  four-point  grading  scale  could  be  applied 
instead  of  a  binary  response.  However,  some  capabilities  still  only  warrant  a 
binary  response  where  relevant.  The  changes  made  are  reflected  in  the  revised 
self-assessment template.

Referring to the definition of ‘Largely compliant’ capabilities, one respondent asked 
whether a capability must always be classified as ‘Materially non-compliant’ if the 
impact of its missing elements is medium to high. The SRB confirms this approach 
is consistent with the definitions of the grading system. 

Qualitative assessments

Respondents  highlighted  the  need  for  further  practical  guidance  to  implement 
the  four-point  self-assessment  grading  scale.  The  SRB  is  of  the  view  that,  given 
the  varying  complexity  of  banks  and  resolution  strategies,  the  ability  to  provide 
uniform  definitions  for  these  assessments  is  challenging  and  should  consider 
bank specific features. Therefore, the SRB invites banks to liaise with their IRTs for 
further clarifications

Single Resolution Board I Feedback statement on the public consultation on resolvability self-assessmentGetting in touch with the EU

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