Question ID:
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Credit risk
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Not applicable
Disclose name of institution / entity:
Type of submitter:
Investment firm
Subject Matter:
Relevance of Issuers Rating for Article 120 of Regulation (EU) No 575/2013 (CRR)

Does Article 120 of Regulation (EU) No 575/2013 (CRR) refer to claims only, where there is an issue-related rating existing, or does it also cover claims, where no rating exists for the issue, but for the issuer?

Background on the question:

Whereas the headline of Article 120 refers to an insitution having a rating (which could be interpreted as an issuer rating), Article 120 (1) refers to "Exposures to institutions with a residual maturity of more than three months for which a credit assessment by a nominated ECAI is available". In this case this sentince could be read that a rating for the exposure must exist (=issue rating) and that a rating for the issue will not be sufficient.

Date of submission:
Published as Final Q&A:
Final Answer:

The availability of a "credit assessment by a nominated ECAI" referenced in Article 120 (1) of Regulation (EU) No 575/2013 (CRR) shall be read as referring to the "exposures" (i.e. to both issuer and issue) referenced in this paragraph. 

The availability of a credit assessment for the exposure and consequently the applicable risk weight for the exposure (i.e. either the risk weight specified in Article 120 or the one specified in Article 121 of the CRR) must be determined in accordance with Article 139 of the CRR It implies that if an issue rating exists as well as an issuers rating, the issue rating should be preferred.


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.

Final Q&A
Answer prepared by:
Answer prepared by the EBA.
Note to Q&A:

Update 26.03.2021: This Q&A has been reviewed in the light of the changes introduced to Regulation (EU) No 575/2013 (CRR) and continues to be relevant.