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List of Q&A's

C_ 08.01.a - qx 2068 – “Retail exposures - Secured by residential real estate”

Should the retail exposures secured by residential real estate to a natural person and the retail exposures secured by residential real estate to an SME both be assigned to the exposure class of “Retail exposures secured by residential real estate” in C_08.01.a qx 2068?

  • 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
  • ID: 2025_7561
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Wording error in IFR/IFD regarding the method for calculating capital requirements for counterparty default risk (K-TCD)

Why is collateral posted to the counterparty ignored in the Exposure Value (EV) calculation for a cleared derivatives portfolio under a margin agreement with a negative Mark-to-Market?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7560
  • Topic: K-factor requirements
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

C02 Own Funds Requirements CA2 - Row 0050 - inconsistent requirements for securitisation positions

The ITS for row 0050 states: "CR SA and SEC SA templates at the level of total exposures", information that hasn't changed between DPM 3.2 and DPM 4.0. The validation rule v0205_m with {tC_02.00.a, default: 0, interval: true}: {r0040} = {r0050} + {r0240} + {r0460} + {r0470} is inactive starting with 3/10/2025 and so far the securitisation positions reported on row0470 column 0010 were considered in the calculation of the row0040. Considering the ITS, are the securitisation positions from row 0470 requested on row0050 in regards of each column 0010 TREA and 0020 S-TREA?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7559
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2025

Loans for ADC (Loan for Acquisition, Development and Construction) with underlying exposure residential mortgage

Considering Basel IV (CRR3) was published after the latest NSFR template instructions. Our interpretation is that there are two possibilities: EBA keep the existing wording allowing only exposures secured by mortgages on residential property or EBA amends the wording for NSFR c80 row 0810 and allows any exposures secured by mortgages and loans on residential property.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7557
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 11/12/2025

Onboarding capacity - Number of applications from new customers over 1 working day

If the bank has a central team managing all account openings within the group, with colleagues assigned to a specific Member State. E.g. two colleagues are dedicated to opening accounts in Luxembourg, how should we clarify the “Onboarding Capacity”, which is defined as the highest number of applications where the institution has validated the request for a bank service? We seek guidance on which of the following approaches would be most relevant: Real statistics-based calculation: if the average daily number of new accounts opened in Luxembourg is 1 (handled by 2 colleagues in the central team), should the onboarding capacity be reported as 1? And if it takes 15 days to onboard new client (handled by 1 colleague or 2 colleagues in the central team)  in Luxembourg then should we report 0 or 0.1 (1 application /10 days)? Full Central Team Capacity (Single Country): if the entire central team were assigned exclusively to Luxembourg, the average daily onboarding capacity could increase to 5. Should this theoretical highest number of 5 be considered for Luxembourg ? Kindly note that in the capacity of the capacity for every other country would be zero as a consequence. How then to report for the remaining countries? Full Central Team + Project Support (Single Country): If the central team had the additional project support (e.g. temporary resources), the average daily capacity for Luxembourg could reach a higher level, e.g. 50. Should such scenarios be considered for “Onboarding Capacity”?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans
  • ID: 2025_7556
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 27/11/2025

Validation rules v23509_h and v23510_h appear incorrect

Are validation rules v23509_h and v23510_h correct?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2025_7555
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Inconsistency between Annotated table CODIS Pillar III and Mapping_tool_including_step_2_tc (incl equity) + Rev 4.1 review_tc

How should we interpret and implement the differences between the Annotated table and the Mapping Tool referring to template CCR4 - K04.00?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR
  • ID: 2025_7554
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2025

v23509_h and v23510_h

Are the validation rules v23509_h and v23510_h correct when reading the reporting instruction of the ITS. In our view the reporting instruction of the ITS is not clear enough.

  • 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
  • ID: 2025_7552
  • Topic: Supervisory reporting
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

C17.01 - v23508_h - Sum of number of events by Basel Business Line

Is the aggregation logic assumed by the control v23508_h applicable in this context?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7551
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

C17.01 - v23507_h - Sum of number events by Basel Business Line

Is the aggregation logic assumed by the control v23507_h is not applicable in this context.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7550
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

C07.00 - v23338_m - RW of 70% empty

The EBA Validation Rule v23338_m applicable to C07.00 COREP template states that the line 210 that concerns the RW of 70% must be empty. Should this control should be applicable?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7549
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

C06.02 - v23688_s - Non negative control

The control indicates that the following columns have to be positive :   c0360 = consolidated own funds   c0370 = of which : common equity Tier 1   c0390 = oh which: contribution to consolidated result Should this control be applicable?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7548
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Validation rule v23688_s requiring only non-negative amounts appears incorrect

Is validation rule v23688_s incorrect? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2025_7547
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Pillar 3 Disclosure: Template EU CQ1: Credit quality of forborne exposures (Col e & f; R090 Loan commitments given ) - Clarification on Mapping Logic

According to the EBA mapping: (Col e & f ; R0090) for row “Loan commitments given” under impairment section are mapped to template F19, which is presented as a positive value in CR1. However, our understanding is that impairment values should be disclose as negative figures in CQ1. Please confirm whether this interpretation is correct. 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7546
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 21/08/2025

Pillar 3 Disclosure: Template EU CR1: Performing and non-performing exposures and related provisions (Column g-l; R150-210 Off balance sheet exposure) - Clarification on Mapping Logic

According to the EBA mapping, columns g to l (rows R150–R210) for off-balance sheet exposures are mapped to template F18, which would be presented as a positive value in CR1. However, our understanding is that impairment values should be disclose as negative figures in CR1. Please confirm whether this interpretation is correct.  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7545
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 21/08/2025

Clarifications about the new column 65 “Offsetting Group” in template C06 under DPM 4.0

Should column 65 (Offsetting Group) in template C06 be reported in 202506?

  • 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
  • ID: 2025_7544
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 12/11/2025

Validation rules taxonomy V4.0 C06.02, v23688_s

The EBA Validation rules taxonomy v23688_s seems not relevant.  

  • 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
  • ID: 2025_7543
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2025

“part of a group”

Does “part of the group” in the meaning of Art. 12 (2) IFR also include investment firms established in a third country?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7542
  • Topic: Capital requirements
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

Reporting of losses from lending collateralised by immovable property (C_15.00)

For loans secured by real estate property with any of the credit history scenarios below, should losses, and in case of scenario iii., exposures, be reported in COREP template C 15.00?  If yes, for which default event or events should the estimated losses be included in the reporting (i.e. is it correct to assume that under scenario ii. only losses estimated for the last default event in the reporting period should be included)?  Also, which default event should be used as a reference date for the reported exposures under scenario i. (the reporting period or the year prior to it) and under scenario ii. (exposure value at the first or at the last default event during the reporting period)? i. scenario:  The loan secured by real estate property had defaulted in a year prior to the reporting period, subsequently it exited/cured from the default state in the reporting period, but later it defaulted again during the same reporting period, and it stayed in the default state until the end of the period. ii. scenario:  The loan secured by real estate property had defaulted in the reporting period, later it exited/cured from the default state in the same reporting period, but still in the same period it defaulted again and stayed in the default state until the end of the period. iii. scenario: The loan secured by real estate property had defaulted in the reporting period and subsequently in the same period the institution stopped recognising the real estate property as CRR-eligible collateral (the real estate property ceased to meet the eligibility criteria).

  • 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
  • ID: 2025_7540
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Credit institutions should not consider as outsourcing

Within Title II, Section 3, Recital 28 Guidelines on outsourcing an exemption what should not be considered an outsourcing is given. Under this exemption can we consider that purchases of goods e.g., standard software or hardware without customization or integration into critical processes, are not outsourcing? For example if the SaaS application is used solely for non-critical, non-banking functions (e.g., HR training platforms, marketing tools), and does not impact the institution’s operational resilience or critical functions, can it be treated from a bank perspective as purchase of goods that fall outside the EBA guidelines on outsourcing arrangements scope?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2019/02 - Guidelines on outsourcing arrangements
  • ID: 2025_7538
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 21/08/2025