Question ID
2025_7592
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Article
Annex V, Part 2
Paragraph
103, 104
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Draft ITS on Supervisory Reporting of Institutions
Article/Paragraph
Annex V, Part 2 103, 104
Type of submitter
Credit institution
Subject matter
FINREP – Loan commitments, financial guarantees and other commitments given
Question

In the context of FINREP template F 09.01, could the EBA clarify whether the scope of columns 0100 and 0110 is intended to include exposures (commitments and certain contractual arrangements that are not commitments as referred to in CRR Article 5/110a/111(4)) that fall under CRR3 Annex I but are not recognised or disclosed under IFRS 9, IFRS 7 or IAS 37?

Background on the question

Under the revised Capital Requirements Regulation (CRR3), the definition of a commitment has been clarified to include any contractual arrangement offered by an institution and accepted by a client and it also introduced the concept of Contractual Agreements that are not commitments. This includes exposures that do not meet the definition of loan commitment under IFRS 9 (e.g. due to revocability) or that are outside of IAS 37 requirements (e.g. due to the absence of a present or possible obligation and contingencies being wholly within the issuer’s control).

Despite not being recognised or disclosed for accounting purposes, such exposures may still be relevant for prudential reporting under CRR3 Annex I and the RTS EBA/RTS/2025/06.

We acknowledge the existence of EBA Q&A 2020_5495, however, it does not explicitly address commitments recognised under the prudential framework that are not recognised or disclosed under IFRS 9, IFRS 7 or IAS 37. EBA Q&A 2017_3478 raises a similar unanswered question.

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because the objective of the Q&A tool is not to answer questions that try to lobby for a modification of the text. However, the issue has already been identified and will be considered for a forthcoming version of the Reporting framework.

The Single Rule Book Q&A tool has been established to provide explanations and non-binding interpretations on questions relating to the practical application or implementation of the provisions of legislative acts referred to in Article 1(2) of the EBA’s founding Regulation, as well as associated delegated and implementing acts, and guidelines and recommendations, adopted under these legislative acts. For further information on the purpose of this tool and on how to submit questions, please see “Additional background and guidance for asking questions”.

Status
Rejected question