Both rules validate the Surplus(+) / Deficit(-) of certain capital:

- v0219_m for CET1 Capital

- v0221_m for T1 Capital

The question stands: Should the range of percentages from Article 465 CRR be implemented in the validation rules for each type of capital or should the fixed percentages in Article 92 CRR be upheld?

According to CRR 465 (1) CRR:

By way of derogation from points (a) and (b) of Article 92(1) the following own funds requirements shall apply during the period from 1 January 2014 to 31 December 2014:

(a) a Common Equity Tier 1 capital ratio of a level that falls within a range of 4% to 4,5%;

(b) a Tier 1 capital ratio of a level that falls within a range of 5,5% to 6%.

The validation rules v0219_m and v0221_m are correct. According to the instructions for row 020 of template C 03.00 of Annex I to Regulation (EU) No. 680/2014 (ITS on Supervisory Reporting) as provided in Part II, chapter 1.4.1 of Annex II to the ITS on Supervisory Reporting, the CET1 capital surplus or deficit shall be calculated without taking into account capital buffers and transitional provisions, i.e. based on a requirement of 4,5%. The same holds true for row 040 of template C 03.00 (T1 capital surplus / deficit) and the requirement of 6% respectively.