CA1 Row 524 Column 010 relates to Article 3 of CRR. Article 3 of CRR, relating to Application of stricter requirements by institutions states: "This Regulation shall not prevent institutions from holding own funds and their components in excess of, or applying measures that are stricter than those required by this Regulation. Can the EBA please confirm if this relates to the difference between Capital Requirement and Capital Holdings? Alternatively is this cell intended to reflect any additional capital holding dictated by competent authorities?
Article 3 does not provide sufficient clarity to allow completion of Row 524 Column 010.
Answer to a)
When calculating the capital ratios according to Article 92(2) of Regulation (EU) No 575/2013 (CRR), institutions may apply, based on Article 3 of CRR, inter alia measures that are stricter than those required by the CRR. Those measures either have an impact on own funds or on total risk exposure amounts. The impact on own funds has to be reported in rows 524 (Core Equity Tier 1 13 CET1), 744 (Additional Tier 1 13 AT1) or 974 (Tier 2) of C 01.00, whereas the impact on the total risk exposure amount has to be reported in row 760 of C 02.00. Only additional amounts resulting from Article 3 of CRR shall be reported in the rows mentioned above (for further details please see the instructions of row 760 of C 02.00).
Answer to b)
Article 3 provides a discretion for institutions to apply a more conservative treatment. It is not the legal basis for decisions of competent authorities to force institutions to hold own funds and their components in excess of or to apply measures that are stricter than those required by this regulation.