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In forceResolution, MREL and TLACLast checked 11 November 2026

Notification that a bail-in recognition clause is impracticable (NOTIF_IMPRACTICABILITY)

A regulatory return listed by the European Banking Authority (EBA), European Union.

Banks must normally put a clause in certain contracts by which the other party accepts that the liability can be written down or converted into shares by a resolution authority (a 'bail-in'). When a bank decides that including that clause is legally or otherwise impracticable, it must tell its resolution authority. These standards set uniform formats and templates for that notification, so authorities can assess it in a consistent way across the EU. Source

Official title: ITS on notifications on impracticability: Commission Implementing Regulation (EU) 2021/1751 of 1 October 2021 laying down implementing technical standards for the application of Directive 2014/59/EU with regard to uniform formats and templates for notifications of determination of the impracticability of including contractual recognition of write down and conversion powers.

Check a Notifications file, freeEvery EBA rule for Notifications, in plain words

The facts

Who files
The institution or entity referred to in Article 1(1), points (b), (c) or (d), of Directive 2014/59/EU (credit institutions and investment firms and the other entities those points cover) notifies its resolution authority (Article 1 of the ITS, for notifications under Article 55(2), first subparagraph, of Directive 2014/59/EU). Notifications are sent on an individual basis (Annex II, Part I). The resolution authority then assesses the determination. Source
How often
Event-driven: a notification is made when the institution or entity determines that it is impracticable to include the contractual recognition term (recital 2 and Article 1). For notified categories of liabilities, a further notification is required if, within 6 months of the notification, the value of liabilities in the category rises by more than 10% of the notified amount (Annex II, template N 01.02, column 0020). Source
Deadline
The ITS sets no fixed remittance date. The notification date is the date the notification is sent to the resolution authority (template N 00.01, row 0020). Template N 02.00 is filled in for the last quarter for which data are available, 'in line with the remittance dates for quarterly reporting: 12 May, 11 August, 11 November and 11 February' (Annex II, point 6.1 and footnote 4). The data exchange format is set by the resolution authority (Article 2(1)). Source
Format
xBRL-CSV, XBRL-XML. Firms file in the data exchange format their national authority sets, following the EBA data point model and its validation rules. Authorities send the data to the EBA in xBRL-CSV only for reference dates from 31 March 2026; for earlier reference dates the EBA accepted xBRL-XML or xBRL-CSV. Source
How it is filed
Filing routes recorded for the EBA: EUCLID (European Centralised Infrastructure of Data); Pillar 3 data hub (P3DH) submissions. See how firms file with the EBA.
Status
In forceThe 4.2 page lists the ITS with 'Status: In force'. The act was published in the Official Journal of 4.10.2021 (L 349) and enters into force on the twentieth day after publication (Article 3). The 4.2 module version applies from reference date 31 March 2026 (the 4.2 page updates 'all other modules' for DPM 2.0 from 03/2026); first_reference_date here is that date. Reporting framework 4.4 phase 1 lists no change to this module. Source
Legal basis
Group
Resolution, MREL and TLAC
Check a file before you file it

Line4 Check for EBA reporting runs EBA's own validation rules on a NOTIF_IMPRACTICABILITY file in your browser, free. Your file never leaves your computer. What it runs, from its published manifest:

  • EBA release 4.2: all 17 of EBA's active checks.

Every EBA rule for Notifications, in plain words

It is not a substitute for the validation the supervisor runs when you submit.

Templates (4)

The tables and forms inside the return. Plain name first, the EBA's code in brackets.

  • Notification Identification (N 01.00)
  • Impracticability of contractual recognition of bail-in by contract/instrument (N 01.01)
  • Impracticability of contractual recognition of bail-in by category (N 01.02)
  • Liability Insolvency Classes (N 02.00)

Templates of module NOTIF_IMPRACTICABILITY in EBA release 4.2, read from the module's entry point in the taxonomy package; parts of a template split into sub-tables (a, b, c) are listed once. Source

Validation rules

8 rules, as counted from the EBA's published material. Software can run them exactly as published. Source

How they are written: Excel list with one row per rule and module version: an expression column in the EBA's DPM-XL syntax, severity (error or warning), active status and reference-date range. The same rules ship as XBRL Formula assertions in the taxonomy package..

EBA's list applies the active NOTIF_IMPRACTICABILITY_4.2 rules to reference dates from 2026-03-31 to 2027-12-30.

The rules, on eba.europa.eu

How they were counted

Distinct rule codes listed for module NOTIF_IMPRACTICABILITY_4.2 in EBA's validation rules list VR_4.4.phase1_.xlsx ((from 4.0) EBA_Validation rules, latest update 12/10/2026) with IsActive = Active: 8 of 8 listed. 0 of the active rules have severity error; the rest are warnings.

Counts are in the EBA's own unit, so they are not comparable with other regulators' counts.

Public data

No published data from this return was found. No publication of this return's data found on the EBA's risk analysis and data pages (checked 2026-11-11). Source

Official documents (14)

The EBA's own files, with the size and SHA-256 fingerprint of each as downloaded on 11 November 2026, so anyone can tell whether a copy is the same version.

  • Legal Act (NOTIF_IMPRACTICABILITY)

    Legal text · PDF · 509.5 KB · 1 October 2021

    Official Journal text (OJ L 349, 4.10.2021); date is the act date printed in the file. Contains the templates (Annex I) and instructions (Annex II).

    SHA-256 f7dc91846238show in fullf7dc918462384bfe67e9749d87b9383156d6f3788f2b3c2ca888d4bff357e908
  • Templates (NOTIF_IMPRACTICABILITY)

    Template · XLSX · 29.3 KB · 5 February 2026

    SHA-256 513f9ddaca98show in full513f9ddaca981b916f7bb051734d86571e68bbcd9c87a106715c1ae5ebf4f980
  • Instructions (NOTIF_IMPRACTICABILITY)

    Instructions · DOCX · 79.2 KB · 5 February 2026

    SHA-256 1f6bde91d681show in full1f6bde91d681598c8fec5c24a47ab6d1fa4b6bad507e5f7e6d8c2f0af5eba154
  • Final report on RTS and ITS on impracticability of contractual recognition of bail-in

    Other · PDF · 446.3 KB · 23 December 2020

    EBA final report (EBA/RTS/2020/13, EBA/ITS/2020/09) explaining the notification process.

    SHA-256 d81e8e121486show in fulld81e8e121486f63941f1447854c31cebbbb79cef91396658b5e069f11ac8cc6b
  • Reporting framework 4.2

    List of returns · HTML

    Table 1.A maps every module of release 4.2 to its legal act, templates and instructions.

  • Taxonomy package 4.2

    Taxonomy · ZIP · 62.0 MB · 13 January 2026

    XBRL taxonomy for all 50 modules of release 4.2, including the validation rules as XBRL Formula assertions.

    SHA-256 0bf9e33720deshow in full0bf9e33720de1472e809417999cfd29e4b5eadb31750c7770622e502590bbdd0
  • Sample files 4.2

    Sample · ZIP · 2.9 MB · 13 January 2026

    SHA-256 41fb8435ce33show in full41fb8435ce33c53528bd05f8624e79acdfc7e6d8991a67870292646fb88cc0ef
  • DPM table layout and data point categorization (4.2.1)

    Template · ZIP · 17.5 MB · 27 February 2026

    Annotated Excel layouts of every template in release 4.2 and 4.2.1, with row and column codes.

    SHA-256 e022598f9f98show in fulle022598f9f98408d6920555a90c899bea5a1a2519b696703c232526a45b7cc07
  • (from 4.0) EBA_Validation rules (latest update 12/10/2026)

    Validation rules · XLSX · 1.1 MB · 12 October 2026

    One row per rule and module version, with the expression, severity, active status and reference-date range.

    SHA-256 38c190fa4c2fshow in full38c190fa4c2ff81f22a5bd2ed94f744fc64e4eb9b722676e07f89669d79b1aea
  • Small validation package 14/09/2026: Micro taxonomy package

    Validation rules · ZIP · 1.5 MB · 14 September 2026

    Severity and deactivation updates for the taxonomy (XBRL set folders).

    SHA-256 ea6184a7e3a6show in fullea6184a7e3a67016346f2154bfb04ca0a489ea829cf344239367fa216d21709f
  • EBA filing rule V5.9

    Filing rules · PDF · 1.2 MB · 26 June 2026

    Technical rules for XBRL-XML and xBRL-CSV files sent to the EBA.

    SHA-256 bbc23b9ecad5show in fullbbc23b9ecad5de0a0821bbe8bce8e4ce617652afce02e81c88d572bac4a4b293
  • DPM Know issues (uploaded on 05/11/2026)

    Known issues · XLSX · 69.9 KB · 5 November 2026

    SHA-256 c6753a428649show in fullc6753a4286496876f2e545b355f1ebaddf0e4383de522b19818c93af141327e0
  • EBA filing rule V5.8

    Filing rules · PDF · 1.1 MB · 25 February 2026

    SHA-256 dea8d520c922show in fulldea8d520c9229c52ae1f44e921a3728d769544e0f0c8937da3958f1c0197d2bf
  • FAQs for Reporting Innovations and Upcoming Releases (Updated on 25/11/2025)

    Guidance · PDF · 196.4 KB · 25 November 2025

    SHA-256 ddcccd9e56f0show in fullddcccd9e56f0c670c5fdeffda7b564dd5a7bf752e990be8e6ed3e2fe7c6fd796

Sources

Every page and document this return's facts were read from.

Knowing exactly what is collected, in what format and under which rules is the first step to real-time supervision. Line4 builds SupTech software for financial regulators that runs checks like these as each return arrives.

Line4's text and records here are free to reuse under CC BY 4.0. Please credit: “Source: Line4 regulatory submissions library (CC BY 4.0), https://www.line4.ai”. The regulators' documents, forms, taxonomies, rules and data belong to them: see EBA's reuse terms. This describes what regulators publish. It is not legal or regulatory advice: always rely on the regulator's own text.

Contains material from the European Banking Authority (EBA), https://www.eba.europa.eu, reproduced with the source acknowledged as the EBA's legal notice requires. Source: European Banking Authority.

Last checked 11 November 2026.