European banks must enhance their capability to assess and report on their liquidity and funding position during a resolution with greater speed, detail, and reliability.
The Single Resolution Board (SRB) launched a public consultation to consolidate and enhance its Operational Guidance on liquidity and funding in resolution. The initiative aims to incorporate lessons learned from ongoing resolvability assessments and recent market events, including the 2023 banking turmoil.
As the central resolution authority for the Banking Union, SRB is responsible for ensuring the orderly resolution of failing banks, aiming to minimize the impact on the economy and public funds. This new guidance is a core part of that mission.
Unlike standard periodic regulatory reporting, liquidity and funding information in resolution is purpose-built for crisis management. It is designed to provide SRB with critical, on-demand data during a bank failure, enabling swift, effective decision-making. This framework moves beyond a theoretical "check-the-box" exercise to a practical test of a bank's true operational readiness.
Once finalized, this new guidance will replace three previous SRB guidance documents on liquidity and funding needs, collateral mobilization, and funding in resolution, consolidating them into a single document. While the SRB states that this does not create new periodic reporting deliverables, it introduces optional templates. They show the expected structure and level of detail, but institutions may use their own systems and formats so long as they can provide the required information effectively.
Key timelines for banks
- Consultation period: 11 May 2026 – 06 July 2026
- Final guidance: Expected Autumn 2026
- Proposed application: From 2027 resolution planning cycle
SRB’s proposed guidance introduces a more demanding and detailed framework for operational readiness.
SRB's stated area of update |
Key change and impact |
| Scope of Key Liquidity Entities (KLEs) | Branches, SPVs, and other entities may be relevant, but are not automatically designated as KLEs. The identification depends on liquidity relevance, resolution group structure, and proportionality. |
| Methodological assumptions for estimating liquidity | The guidance mandates testing against more severe scenarios, specifically a "fast-moving" scenario where a crisis unfolds in less than one month. |
| Governance expectations on the liquidity situation | Banks must have the capability for high-frequency, on-demand reporting, with the ability to deliver detailed liquidity data within a 24-hour timeline. |
| Collateral-related expectations | The focus shifts to all available collateral, with a new requirement to estimate and report the "time-to-mobilize" for each asset class. |
The definition of "Key Liquidity Entities" (KLEs) has been significantly expanded beyond material legal entities to include any entity critical to group liquidity, including branches and Special Purpose Vehicles (SPVs). Banks have the option to use the new Annex II template, which covers both KLEs and Key Liquidity Drivers (KLDs), to map these entities and their intricate funding dependencies, requiring a complete, group-wide view.
Banks must now adopt a more sophisticated methodology to calculate their Liquidity in Resolution Estimate (LRE). This involves forecasting the net liquidity position by modeling the behavior of all KLDs, such as deposit outflows, credit line drawdowns, and derivative-related payments, under a severe stress scenario. The methodology must now account for modern risks and capture peak intraday liquidity needs.
SRB is moving beyond theoretical planning to practical testing. Banks must now prove their capabilities through liquidity data collection & capability testing exercises that simulate both "slow-moving" (12+ months) and "fast-moving" (within one month) crisis scenarios. Success is measured by the ability to provide accurate, granular data on-demand, demonstrating that resolution plans are operationally sound. The data for these capability tests is currently reported via the SRB's CASPER portal.
To ensure access to all potential funding sources in a crisis, including the Single Resolution Fund (SRF), which provides liquidity on a fully collateralized basis, the framework assumes a bank's best assets will already be encumbered. The new Annex III template indicates the expected level of information on available collateral and the estimated "time-to-mobilize" for different asset classes. However, institutions can use their own systems and formats where they can provide the required information effectively.
The SRB's enhanced expectations create operational and data management hurdles that legacy systems and manual processes cannot easily overcome.
Regnology provides end-to-end regulatory risk solutions to help banks address the SRB's demanding expectations for liquidity and funding in resolution.
Our cloud-native solutions support the workflow from data aggregation to the preparation of structured information. Built on a unified, granular data model, our platform helps banks connect information across Risk, Finance, and Treasury and create a consistent view of liquidity needs, funding constraints, and collateral availability. Where required by the institution, Annex II and Annex III can also be set up in the solution.
By integrating advanced ALM and scenario analysis capabilities, we empower banks to conduct the rigorous stress testing required by the SRB, model complex liquidity risks, and deliver accurate, on-demand reporting with confidence.
This guidance applies to all banks under the direct remit of the Single Resolution Board (SRB), in particular significant institutions and relevant cross-border groups for which resolution is the preferred strategy.
The main differences are the demand for faster, short-notice reporting capabilities, including within 24 hours where required, the focus on more severe "fast-moving" crisis scenarios, and the need for more granular data on collateral mobilization and group-wide liquidity structures (KLEs).
A "fast-moving" scenario is one where a bank enters resolution within one month of the crisis onset. It reflects recent banking turmoil, where confidence can deteriorate rapidly, and liquidity stress can emerge very quickly, potentially amplified by digital banking and social media.
Yes, the guidance incorporates the principle of proportionality. For example, for banks with a Multiple Point of Entry (MPE) strategy, liquidity expectations apply at the level of each resolution group, which is expected to manage its liquidity independently, without relying on funding from other parts of the wider group in a crisis.
The SRB wants to ensure that a bank's resolution plan is not just a theoretical document but can be practically executed under pressure. These exercises test a bank's data systems, governance, and operational readiness in a simulated crisis environment.
Insight
Learn why financial institutions must evolve their funding liquidity strategies to thrive in a climate defined by volatility, regulatory pressure, and rising depositor stress.
Read moreInsight
The future of regulatory risk and reporting isn’t just automation: it’s intelligent orchestration. In our new whitepaper with Chartis, we detail how financial institutions can build a true strategic capability.
Read moreInsight
The EBA’s simplification package is not a reduction exercise; it is a structural shift. Our new discussion paper analyzes the move from fragmented reports to an integrated data architecture.
Read more
© 2026 Regnology Group GmbH All Rights Reserved
DE 
FR 
