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Q&As refer to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.

Please note that the Q&As related to the supervisory benchmarking exercises have been moved to the dedicated handbook page. You can submit Q&As on this topic here.

List of Q&A's

Risk weighting attributed to gold in the form of a commodity

Is the definition of 'gold bullion', as recently amended by Regulation (EU) 2024/1623, consistent with the previous definition of 'gold' under Regulation (EU) No 575/2013 (CRR), as clarified by EBA Q&A 2016_3011, in the sense that it includes all forms of gold commodities (such as bars, ingots, jewels, manufactured products, and coins) whose value is determined exclusively by gold content—defined by purity and mass—regardless of their form, provided that no numismatic, artistic, branding, or other extrinsic value is attributed?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Clarification on Risk Weight Assignment for ADC Exposures in Default

Could you please clarify what risk weight should be applied to ADC exposures that are in default?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Validation rules taxonomy V4.0 C_08.01.a,C_09.02 - v0418_m

The validation rule formula v0418_m specifies that the Risk Weighted Assets (RWA) reported under form 09.02 for IRB exposure class central governments and central banks of all country should be less than or equal to RWA reported under form C_08.01.a, column 0255 where Sheets are in qAE:qx2021 (Central governments and central banks with own estimates of LGD and/or conversion factors), qAE:qx2020 (Central governments and central banks without own estimates of LGD or conversion factors), qAE:qx2014 (Corporates - Specialised Lending without own estimates of LGD or conversion factors), qAE:qx2055 (Retail exposures - Purchased receivables - with own estimates of LGD or conversion factors). The Sheet qAE:qx2014 and qAE:qx2055 should not be considered in the formula for comparison of exposure to central government and central bank. These two sheet’s codes are also not part of validation rule v0415_m and v0416_m where the similar comparison is made for original exposure and Exposure at Default (EAD). The control seems incoherent.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Calculation of minimum lease payments in case of operational lease

Does the EBA acknowledge that the residual value should be discounted, or the interests on this residual value should be filtered out of the calculation of the discounted minimum lease payments, to avoid an increase of the exposure beyond the accounting value?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Multilateral development banks classification for the purpose of article 325ah

Buckets 2 and 11 of Table 4 in Article 325ah refer to the category of multilateral development banks (MDBs) and international organisations (IORGs) referred to in Article 117(2) or Article 118 of CRR. At the same time, paragraph 2 of the same article 325ah, requires the use of a classification that is commonly used in the market for grouping issuers by sector, in order to assign a risk exposure to a sector.  Assuming that such a market wide accepted classification would show a certain counterparty as an MDB, as long as this specific counterparty is not listed in the above listed articles mentioned for buckets 2 and 11 of Table 4 in Article 325ah (as a one to one match) , then this counterparty would need to be assigned to a different bucket, likely 4 or 13.  Can there be a departure from the specific list of MDBs and IORGs, as referred to in Article 117(2) or Article 118 of CRR, for the purpose of Table 4 in Article 325ah of CRR? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Application of formulae v23061_m on r0180

Could you please confirm that the formulae v23061_m needs to be modified and should apply to all rows except r0180?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

currencies Lithuanian Litas and Croatian Kuna

In C 22.01 the currencies Lithuanian Litas and Croatian Kuna are still available in the Annotated templates, while removed from C_2024_8389_1_ANNEX_EN_V3_P1_3682615.XLSX, which was published after the Annotated templates. Can we assume these 2 currencies should be removed?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Financial Conglomerates: Mismatch between ITS and DPM 3.5 – ID v22748_u - T1 L 06.00, column c0020.

We are seeking clarification about a possible mismatch between ITS and DPM 3.5 (ID v22748_u - T1 L 06.00, column c0020) as part of the compilation of the template FC.06 Template - “Risk Concentration - Exposure by counterparties" within the FiCod. supervisory reporting. The Commission Implementing Regulation (EU) 2022/2454 of 14 December 2022 states that, within the Template FC.06 - “Risk Concentration - Exposure by counterparties", the exposures must be reported for each individual legal entity belonging to the financial conglomerate, whereas the DPM 3.5 only permit reporting a unique value of the identification code of the external counterparty. This also determines the impossibility of representing separately the exposures held towards the same external counterparty but denominated in different currencies. We therefore ask what is the correct way to represent - inside the FC.06 Template- the cases in which multiple entities belonging to the conglomerate have exposures towards the same external counterparty and for the cases in which, for each external counterparty, there are exposures denominated in different currencies.

  • Legal act: Directive 2002/87/EC (FiCoD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2454 – ITS on the reporting of intra-group transactions and risk concentration for financial conglomerates

v7364_m

Is v7364_m complying with the CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

SME

In the instructions for Finrep ITS consolidated - Annex V to EU Regulation 2021/451 - there is a definition of SME in point 5.i ‘SME’: micro, small and medium-sized enterprises as defined in Commission Recommendation C(2003)1422 (6); (Commission Recommendation of 6 May 2003 concerning the definition of micro, small and medium-sized enterprises (C(2003)1422) (OJ L 124, 20/05/2003, p. 36), where in article 1: “Enterprise An enterprise is considered to be any entity engaged in an economic activity, irrespective of its legal form. This includes, in particular, self-employed persons and family businesses engaged in craft or other activities, and partnerships or associations regularly engaged in an economic activity.” In accordance with the above-mentioned recommendation and SME definition, the scope  of enterprises also includes self-employed individuals. Given that SME are reported in FINREP ITS as enterprises,  should self-employed entrepreneurs be treated as enterprises as well?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

Calculation of the Countercyclical Capital Buffer

Clarification  to EBA Q&A 2016_3050 and CRM techniques with substitution effects How do we have to consider CRM techniques with substitution effects on the exposure in the CCB?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Recognition of non-transferable liquidity held by and arising in third country subsidiaries in the context of the calculation of the consolidated LCR

What is the (combined) treatment of liquid assets held by and liquidity inflows arising in third country subsidiaries being subject to transfer restrictions for the purpose of the calculation of the LCR at consolidated level?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement

C_25.01.b Datapoint Modelling

The datapoint modeling for C_25.01.b does not align for rows 10 & 20 with that of C_25.01.a. The datapoint model for C_25.01.a lists (qAFF:qFI) Type of Financial Instruments while C_25.01.b does not. 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

XBRL Modelisation of FICOD REPORTING L0600

It seems that the current modelisation L0600 only accepts as a dynamic dimension the column 0020 "identification code of the exernal counterparty" where the ITS states that :  -1) General ITS : "the aim is to list the significant exposure [...] by single counterparty outside the scope of the financial conglomerate. If more than one entity of the financial conglomerate is involved, for entity a separate line is necessary"  2) ITS L0600 - c0080 :  The name of the enity of the conglomate involved in the exposures. It concerns all entities and for each entity a separate entry has to be reported. If more than one entity of the conglomerate is invoved, for each entity a separate line is necessary.   So normally the report shoud have two key dynamisms a the row level : 0020 "identification code of the exernal counterparty" 0080 "Entity of the financial conglomerate' Can you confirm that with the current XBRL settings it's not possible to correctly submit the informations as expected by the ITS? Can you propose a workaround ?

  • Legal act: Directive 2002/87/EC (FiCoD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Correct classification of services related to the 'reselling' of software provided in SaaS mode

With reference to the correct identification of the type of ICT services, taking into account the types contained in ANNEX III of Regulation (EU) 2024/2956, how should services related to the 'reselling' of software provided in SaaS mode be classified?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information

Table F12.01 – Movements in allowance and provisions for credit losses

Considering the greyed out columns in row 350 and 550: How can the actual movement of impairment be reflected correctly?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

v4769_m and v4770_m rules

We inform you that the v4769_m and v4770_m rules of the EBA 4.0 taxonomy, which verify that the “TOTAL” exposure class is equal to the sum of the exposure subclasses, are incorrect because the “Memo item” exposure classes of the C_08.01 report are wrongly included in the sum.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Register of Information Taxonomy reporting vs ITS on Register of Information

In the industry workshop of 18 of December 2024, which was a summary of Dry Run, it was stated that the reporting taxonomy provided shall be used for the reporting , while the current DORA 4.0 validation rules does not follow the instructions provided in the ROI ITS. We kindly ask you to confirm if the reporting shall follow the DORA 4.0 validation rules despite the mismatch with the ROI ITS. Differences between the law and the taxonomy: Requirement in Law Requirement in Taxonomy Additional question   B_01_01_0010 stated as non-nullable, but is mentioned as nullable in "LEI - EUID checks VR-2"     B_01_02_0010 stated as non-nullable, but is mentioned as nullable in "LEI - EUID checks VR-12"   B_02.03 does not include an extra column c0030 b_02.03 has a column c0030, that is required to be filled out What is the extra column used for? B_03.01 does not include an extra column c0030 b_03.01 has a column c0030, that is required to be filled out What is the extra column used for? B_03.03 does not include an extra column c0031 b_03.03 has a column c0031, that is required to be filled out What is the extra column used for? B_04.01 clarifies that column c0040 is only mandatory if the financial entity making use of the ICT service(s) is a branch of a financial entity (B_04.01.0030) B_04.01 column c0040 is mandatory. Which also requires at least 1 branch in B_01.03. What should be reported if a reporting entity does not have any branches? Should both B_01.03 and B_04.01 be empty. Or? B_05.01 c0030 & c0040 is optional B_05.01 c0030 & c0040 is required when c0070 = Legal person, excluding individual acting in a business capacity   B_05.01 c0110 is mandatory if the ICT-third party service provider is not the ultimate parent undertaking B_05_01_0110 is mandatory all the time according to the DPM   B_05.02 column c0060 & c0070 is mandatory, but not applicable for rank 1. An empty value should be reported if rank = 1  B_05.02 column c0060 & c0070 is always required. What should be reported in c0060 & c0070 if the rank = 1? B_01_01_0050 is mandatory in case of reporting B_01_01_0050 is always mandatory   B_01_01_0060 is mandatory in case of reporting B_01_01_0060 is always mandatory   B_01_02_0060 is mandatory B_01_02_0060 is optional in DPM   B_02_01_0030 is mandatory B_02_01_0030 is optional in DPM   B_02_02_0040 is mandatory B_02_02_0040 is optional in DPM   B_02_02_0130 is mandatory if the ICT service is supporting a critical or important function B_02_02_0130 is optional in DPM   B_02_02_0140 is mandatory if the ICT service is supporting a critical or important function B_02_02_0140 is optional in DPM   B_02.02.0150 is mandatory if Yes is reported in c0140 B_02.02.0150 is mandatory in DPM   B_02.02.0160 is mandatory if the ICT service is based on or foresees data processing B_02.02.0160 is mandatory in DPM   Additional to the question above: If changes will be made to the Taxonomy, when will these be made available? Do you foresee to apply changes to solve the aforementioned mismatch? If so, can you please share when this is expected to be done? If the current Taxonomy, DORA 4.0, must be followed for reporting, can we expect that all local authorities are required to accept the Register of Informations in the format aligned with the Taxonomy? We have experienced differences while doing a mock exercise to submit the reports to local authorities from the reporting technical package. To our knowledge, these discrepancies shall not exist and the national authorities to which entities have to report to are required to accept files that follow the reporting technical package. In this scenario, what actions can we expect to be taken?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information

COREP_OF, C_10.00, modelling on columns c0090 and c0100

How shall institutions report information in COREP_OF, table C.10.00, columns c0090 and c0100?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions