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EBA E-mail alert October 31, 2025

News & Press

Persistent differences in national loan recovery outcomes reinforce case for EU insolvency harmonisation, the EBA analysis finds

Press Release

The European Banking Authority (EBA) today published its second Report on the benchmarking of national loan enforcement frameworks across the EU Member States. The Report, which was compiled in response to the EU Commission’s call for advice in the context of the Savings and Investment Union’s agenda, calculates the benchmarks for loan recovery outcomes for the EU 27 aggregates and for the individual Member States. The results highlight a high degree of dispersion among different categories of loans, and across the EU27 Member States, for most of the benchmarks and loan categories. In addition, the Report underscores the importance of certain elements related to both the legal framework and the judicial capacity to improve the recovery outcomes.

Final Q&As

Question ID: 2025_7350

Topic
Credit risk
Subject matter
Calculation of the SME supporting factor for off-balance-sheet exposures

Is the SME supporting factor applicable, and if so, how shall it be computed, in case there is no on-balance-sheet exposure to be included in E*, as defined in Article 501(1) of CRR?

Question ID: 2025_7382

Topic
Credit risk
Subject matter
AIRB combined with Financial Collateral Comprehensive Method

Article 223 para 4 subpara (b) indicates that banks using the A-IRB approach can also utilize the Financial Collateral Comprehensive Method (FCCM). Does the EBA agree with this?  

Question ID: 2025_7479

Topic
Market risk
Subject matter
Exclusion of back-to-back positions from RRAO

Under the provision of Art. 325u(4)(c) CRR, how should perfectly offsetting positions be treated in different constellations (concretely, the instruments comprising the two offsetting positions can have either a ‘one-to-one (1:1)’ relationship or a ‘many-to-many (m:n)’ relationship) in terms of excluding them from the own funds requirements for residual risks?

Question ID: 2025_7514

Topic
Transparency and Pillar 3
Subject matter
Clarification on column a) "Total exposures", CR7-A Template

Could you please confirm that the coloumn a) "Total exposures" of CR7-A template should be filled with outstanding amount post application of credit conversion factor without taking into account any substitution effects due to the existence of a guarantee  in accordance with Articles 166 to 167 CRR, in case the exposure covered by only unfunded credit protection (guarantees)?

Question ID: 2025_7533

Topic
Transparency and Pillar 3
Subject matter
Disclosure of liquidity requirements - NSFR - LIQ2. Periodic data to be disclosed in the Disclosure Period

Further to the publication of the P3DH Framework, we would like to clarify the expectation around the periodic data to be disclosed within the Disclosure Period, relating to the NSFR LIQ2 template.

As part of the Taxonomy 4.1 Release and the publication of the associated 'Annotated Tables', it is apparent that firms will be required to disclose 4-quarters worth of data, so 'T', 'T-1', 'T-2' and 'T-3'. At present, it is apparent that firms across the EU have interpreted the CRR in different ways when reviewing their Pillar 3 Disclosures for this template. For example, for year-end related disclosures we are observing a combination of : a) a 'spot' year-end position; b) a year-on-year comparison or c) a quarter-on-quarter comparison across Financial Institutions.

The CRR guidance states the following: 

3.   Institutions shall disclose the following information in relation to their net stable funding ratio as calculated in accordance with Title IV of Part Six:
(a) quarter-end figures of their net stable funding ratio calculated in accordance with Chapter 2 of Title IV of Part Six for each quarter of the relevant disclosure period;

We take this to mean the 'quarter-end' periods within the current disclosure year, rather than a 'rolling' quarter-end view. Note that when we refer to a 'rolling' quarter view, for example when disclosing at HY (half-year) 2024, this would include Q3 and Q4 from 2023, together with Q1 and Q2 from 2024.

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