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RegisterBench

v8870_m - Start date required when the row contains any other data (B_02.02)

If any other data column in a B_02.02 row is filled, the start date of the contractual arrangement (c0070) must be filled too.

Layer
W2
Severity
warning
Templates
B_02.02
Columns
c0070
Taxonomy version
eba-4.0-errata5
Status as of
2026-06-23
Status
founder-approved

Reviewed at gate 1 (founder) on

Content last changed

Official expression (EBA, verbatim)

with {tB_02.02, default: null, interval: false}: if ( not ( isnull ({c0040}) ) ) or not (( isnull ({c0080}) )) or not (( isnull ({c0090}) )) or not (( isnull ({c0100}) )) or not (( isnull ({c0110}) )) or not (( isnull ({c0120}) )) or not (( isnull ({c0140}) )) or not (( isnull ({c0170}) )) or not (( isnull ({c0180}) )) then ( ( not ( isnull ({c0070}) ) )) endif

Precondition (verbatim): {v_B_02.02} - the rule is evaluated only when template B_02.02 is part of the filing (its filing indicator is true).

Description in the EBA artifact: empty (NULL).

What this rule checks

Template B_02.02 (Contractual arrangements - Specific information) details each contractual arrangement per entity, provider and ICT service. The row key is composite - eight columns: c0010 (Contractual arrangement reference number), c0020 (LEI of the entity making use of the ICT service(s)), c0030 (Identification code of the ICT third-party service provider), c0050 (Function identifier), c0060 (Type of ICT services), c0130 (Country of provision of the ICT services), c0150 (Location of the data at rest (storage)), c0160 (Location of management of the data (processing)). A finding on this template carries all eight key values.

The rule looks at each row: if at least one of the data columns is filled - Type of code to identify the provider (c0040), End date of the contractual arrangement (c0080), Reason of the termination or ending (c0090), Notice period for the financial entity (c0100), Notice period for the ICT third-party service provider (c0110), Country of the governing law (c0120), Storage of data (c0140), Sensitiveness of the data stored (c0170), Level of reliance on the ICT service (c0180) - then c0070 (Start date of the contractual arrangement) must be filled as well. A row that carries only the eight key columns does not trigger the rule.

This rule checks only that c0070 is filled. The date format itself (yyyy-mm-dd) is a separate, format-level check. No active W2 rule compares the two dates of the row: the relation "end date after start date" was guarded by v8816_m, which is inactive on the current EBA list.

This is a warning-level check (layer W2, severity: warning). It does not technically block or reject a filing at the ESAs - a technical rejection can only be caused by the structural file checks (STRUCT layer). A violation shows up as a warning in the validation feedback. The rule is active on the current EBA validation rules list (status as of 2026-06-23).

Most common causes

  • The row was filled in starting from the code type or the governing-law country and the start-date cell was left empty.
  • The row was created with the eight key columns only, other columns were filled in later and the start date was never added.
  • A column shift in a CSV or Excel export left c0070 empty and moved values into neighbouring columns.

How to fix it, step by step

  1. Open template B_02.02 and find the flagged row. The finding gives the row number and all eight key values (c0010, c0020, c0030, c0050, c0060, c0130, c0150, c0160).
  2. Enter the start date of the contractual arrangement in column c0070 in the yyyy-mm-dd format, for example 2023-02-13.
  3. If the whole row is there by mistake, delete the entire row instead. A row that carries only the eight key columns does not trigger this rule.
  4. Run the validation again and confirm the v8870_m warning for that row is gone.

Example: fails vs passes

Key of the row in both tables (all eight key columns filled): c0010 CTR-0001, c0020 549300Q5EH2NP82EPE32, c0030 DUMMYLEI123456789012, c0050 F-001, c0060 eba_TA:S19, c0130 eba_GA:PL, c0150 eba_GA:PL, c0160 eba_GA:IE.

Fails - the type of code is filled, the start date is empty; the finding points at column c0070 of this row:

c0040 (Type of code to identify the ICT third-party service provider) c0070 (Start date of the contractual arrangement)
eba_qCO:qx2000 (empty)

Passes - the start date is filled:

c0040 (Type of code to identify the ICT third-party service provider) c0070 (Start date of the contractual arrangement)
eba_qCO:qx2000 2023-02-13

Also passes (edge case) - a key-only row: all eight key columns are filled and none of the data columns has a value, so the condition never activates. With several rows, only the incomplete row is flagged - the finding carries its row number and all eight key values.

  • v8871_m - the twin date rule on B_02.02: it requires c0080 (End date of the contractual arrangement) under the same trigger.
  • v8869_m - the same row-completeness family on B_02.02: it requires c0040 (Type of code to identify the ICT third-party service provider).
  • v8816_m - date relation on the same pair: c0080 must be later than c0070 (inactive on the current EBA list).
  • e23680_e - existence rule on the columns c0040-c0080 of B_02.02, including c0070 (inactive on the current EBA list).

Fix it in the RoI Builder - it points at the exact row and cell and re-checks as you type.

This page describes what the software does. It is neither legal advice nor an interpretation of any regulation, and using the product does not by itself make any submission complete, correct or acceptable to any authority. The responsibility for what is filed stays with the entity that files it.