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2 min readWarningEBA reporting framework 4.2Updated 10 November 2026

Eligible liabilities subordinated to excluded liabilities must equal the sum of its five parts (M 02.00.a, EBA rule v10761_m)

A warning in the loss-absorbing capacity return (MREL and TLAC), on template M 02.00.a, mREL and TLAC capacity and composition (resolution groups / entities) (TLAC1) (I).

Check your file against this ruleWhat to do if it fails

The rule in plain words

Eligible liabilities subordinated to excluded liabilities must equal these five added up:

  • Eligible liabilities instruments issued directly by the resolution entity (not grandfathered)
  • Eligible liabilities instruments issued by other entities within the resolution group (not grandfathered)
  • Eligible liabilities instruments issued prior to 27 June 2019
  • Tier 2 instruments with a residual maturity of at least one year to the extent they do not qualify as Tier 2 items
  • (-) own eligible liabilities instruments subordinated to excluded liabilities

EBA checks it for two columns: minimum requirement for own funds and eligible liabilities (MREL), and requirement for own funds and eligible liabilities for G-SIIs (TLAC). That makes two checks. A failure names the one that failed.

How the Line4 Check report words itShow

The first of its checks, word for word as the report shows it when it fails. The others read the same, with their own column, row or sheet.

Minimum requirement for own funds and eligible liabilities (MREL): Eligible liabilities subordinated to excluded liabilities = Eligible liabilities instruments issued directly by the resolution entity (not grandfathered) + Eligible liabilities instruments issued by other entities within the resolution group (not grandfathered) + Eligible liabilities instruments issued prior to 27 June 2019 + Tier 2 instruments with a residual maturity of at least one year to the extent they do not qualify as Tier 2 items + (-) Own eligible liabilities instruments subordinated to excluded liabilities

What to do if your filing fails it

  1. 01Open the template below and find the cells the rule reads.
  2. 02Add up the parts in your file and compare the result with the total.
  3. 03If they differ, a part is missing, a value sits in the wrong cell, or the total is out of date.
  4. 04EBA allows a small rounding difference, worked out from the decimals each value is reported with.
  5. 05It runs only when your filing indicators mark M 02.00 as reported.
  6. 06This is a warning. It does not stop the filing on its own, but your authority may ask you to explain it.

The cells it reads

MREL and TLAC capacity and composition (resolution groups / entities) (TLAC1) (I) (M 02.00.a)

Rows

  • 0090Eligible liabilities subordinated to excluded liabilities
  • 0100Eligible liabilities instruments issued directly by the resolution entity (not grandfathered)
  • 0110Eligible liabilities instruments issued by other entities within the resolution group (not grandfathered)
  • 0120Eligible liabilities instruments issued prior to 27 June 2019
  • 0130Tier 2 instruments with a residual maturity of at least one year to the extent they do not qualify as Tier 2 items
  • 0132(-) Own eligible liabilities instruments subordinated to excluded liabilities

Columns

  • 0010Minimum requirement for own funds and eligible liabilities (MREL)
  • 0020Requirement for own funds and eligible liabilities for G-SIIs (TLAC)

A worked example

The first of its checks, with simple numbers.

Illustrative values
Eligible liabilities instruments issued directly by the resolution entity (not grandfathered)1,200
Eligible liabilities instruments issued by other entities within the resolution group (not grandfathered)800
Eligible liabilities instruments issued prior to 27 June 2019450
Tier 2 instruments with a residual maturity of at least one year to the extent they do not qualify as Tier 2 items300
(-) own eligible liabilities instruments subordinated to excluded liabilities150
Together2,900
What the rule then expects

Eligible liabilities subordinated to excluded liabilities must then be 2,900.

2,900Passes
3,000Fails

A file that reports 2,900 passes. One that reports 3,000 fails, by 100.

The numbers are illustrative, reported to the unit, so the rounding tolerance does not change the result.

Show the rule as writtenShow

EBA's formula, as written out for the first of its checks. Cells are written as {template, row, column, sheet}.

{M_02.00.a,r0090,c0010,} = {M_02.00.a,r0100,c0010,} + {M_02.00.a,r0110,c0010,} + {M_02.00.a,r0120,c0010,} + {M_02.00.a,r0130,c0010,} + {M_02.00.a,r0132,c0010,}

The next one:

{M_02.00.a,r0090,c0020,} = {M_02.00.a,r0100,c0020,} + {M_02.00.a,r0110,c0020,} + {M_02.00.a,r0120,c0020,} + {M_02.00.a,r0130,c0020,} + {M_02.00.a,r0132,c0020,}

Every MREL and TLAC rule, by template

Checks like this one, run at the point of submission, are the first step to real-time supervision.