The EACB appreciates the opportunity to comment on the EBA draft ITS on provisions of information for the purposes of resolution plans in the context of Directive 2014/59/EU. We welcome the EBA efforts in performing a comprehensive review of the current ITS in order to foster further harmonisation, review possible overlaps, build on good practices and address shortcomings identified in the current framework.
However, we still believe that the resolution authority's discretion in determining the scope of further reporting is detrimental to IT efficiency and data planning and counters the idea of improving overall harmonisation and efficiency. In our understanding, the ITS reporting requirements are sufficient to satisfy the needs of resolution authorities and to comply with their mandate in “business-as-usual situations”. For this reason, we envisage that a clearer and more detailed description of the circumstances under which the resolution authority might require additional information for the purpose of individual or group resolution plans might be necessary to ensure full alignment of the ITS with the principles indicated above and reduce uncertainty for the actors.