The 180 days shall not apply for the purposes of Article 127 of Regulation (EU) No 575/2013 (CRR) according to Article 178(1)(b) of CRR. When assessing the regulatory capital implications of this provision, please note that the legal implications of classifying exposures as defaulted differ between the Standardised and the IRB approach.
This question goes beyond matters of consistent and effective application of the regulatory framework. A Directorate–General of the Commission (Directorate General for Internal Market and Services) has prepared the answer, albeit that only the Court of Justice of the European Union can provide definitive interpretations of EU legislation. This is an unofficial opinion of that Directorate General, which the European Banking Authority publishes on its behalf. The answers are not binding on the European Commission as an institution. You should be aware that the European Commission could adopt a position different from the one expressed in such Q&As, for instance in infringement proceedings or after a detailed examination of a specific case or on the basis of any new legal or factual elements that may have been brought to its attention.