Addendum to the Circular for Credit Institutions on MREL Reporting issued on 7 February 2023

While the addendum is technical in nature, it signals that supervisory expectations around resolution-reporting data quality, granularity and consistency are being refined rather than relaxed. For compliance, treasury and regulatory-reporting teams, the practical implication is that existing MREL reporting builds, data lineage documentation and validation controls may need to be re-checked against the amended instructions. Firms should treat this as a controlled-change event: confirm which templates, fields or submission mechanics are affected, map the change to owners, and evidence reconciliation between the MREL stock of eligible liabilities and underlying liability/issuance records.

Where third-party systems or group-level reporting platforms generate MREL outputs, change-impact assessments should be raised with those providers promptly. Resolution planning teams should also verify that internal MREL monitoring, breach-escalation triggers and board-level MI remain aligned with the revised reporting basis. Actionable takeaways: (1) obtain and read the addendum in full and diff it against the 2023 circular; (2) update the regulatory change log and assign accountable owners with target completion dates ahead of the next reporting reference date; (3) re-run dry-run submissions and quality assurance; (4) brief the ILAAP/resolution planning committee and internal audit; (5) consider a voluntary engagement with the MFSA if interpretation points are unclear.

Risk of inaction is modest but real: misaligned or late MREL submissions invite supervisory challenge, remediation costs and potential knock-on effects for resolution assessments. Firms with cleaner, better-automated liability data can convert this into an advantage by shortening future change cycles.