Search for Q&As

Enquirers can use various factors to search for a Q&A:

  • These include searching by the Q&A ID; legal reference, date submitted, technical standard / guideline, or by keyword if known.
  • Searches can be extended to more than one legal act, topic, technical standard or guidelines by making multiple selections (i.e. pressing 'Ctrl' on your keyboard, and selecting the relevant ones from the drop-down lists by left mouse-click).

Disclaimer:

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.

Final Q&As Q&As under review Rejected Q&As Archived Q&As All Q&As

List of Q&A's

Z 09.01 – FMI Services – providers and users (RESOL2)

We ask confirmation that the column “0140-Resolution resilient contract” applies only in the case of indirect access to FMIs and that for FMIs with direct access, the value “Yes” should be reported

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7705
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 13/03/2026

Reporting of the penalty fees in J07.00 Repricing cash flows (behavioural template)

How should the penalty fees be treated in J07.00 Repricing cash flows (behavioural) template? At this point, the inclusion of penalty fees will break the validation rule v22322_m.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2026_7704
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 05/03/2026

Resolution Reporting on FMI

With reference to Resolution Reporting on FMI Services, we would like to bring to your attention some questions regarding the scope and data reported, particularly in cases where the Bank participates indirectly in certain FMIs. With reference to item "Z 09.03 - Financial Market Infrastructure Services (FMI) - Key Metrics (FMI 3)", we would therefore like to know whether, for FMIs to which we participate indirectly, it is possible to report intermediary data instead of individual FMI data, and, if so, how to complete the individual items. The question specifically concerns the following reporting fields: • Z 09.03/60-70 Value of positions on proprietary and client accounts • Z 09.03/80 Number of clients covered by omnibus accounts • Z 09.03/90 Number of clients covered by segregated accounts • Z 09.03/100-110 Number of transactions on proprietary and client accounts • Z 09.03/120-130 Value of transactions on proprietary and client accounts This requirement arises from the fact that, since we use an intermediary, we do not have internal evidence of the final FMIs on which it relies. In fact, our systems only map the intermediary's reference, while the references of the final FMIs are not tracked. As an example, we can cite Intesa San Paolo, which acts as an intermediary for Banca Mediolanum on all CSDs and most trading venues. In our systems, Intesa San Paolo is matched to all securities transactions, without specifying the final CSD. We currently report that we are still providing the above-mentioned information by requesting detailed data from our intermediaries. In this regard, we also note that our intermediaries will include our data in their reporting for individual FMIs, reporting us as their clients in these contexts.   Finally, we would like to take this opportunity to request clarification regarding some new items introduced starting this year, specifically: • Z 09.01/80 Operator of the FMI - is it correct to indicate the contractual contact person of the FMI/Intermediary? • Z 09.04/20 Product Type - Is it possible to include a description of the service provided by the FMI/intermediary, consistent with that indicated in item Z 09.01/220 - Services provided by FMI/intermediary, possibly with greater detail? • Z 09.04/30 Substitutability - Should the substitutability analysis be performed for all FMIs, considering as alternative FMIs/intermediaries only those with which a contract at the conglomerate level is already in place?  

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7702
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 13/03/2026

Incorporation of historical data from integrated entities when historical information is not representative of current underwriting standards

Should an institution incorporate historical default data from acquired or merged entities into its IRB model estimates for PD, LGD, and CCF when calculating RWA for the acquiring institution’s exposures originated before and after the merger? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/16 - Guidelines on PD estimation, LGD estimation and the treatment of defaulted exposures
  • ID: 2026_7701
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 31/03/2026

EBA mapping file for Pillar 3 template EU CMS2

The mapping file for EU CMS2 template seems to contain multiple issues: 1) The Naming of the row EU 7a does not conform to the regulation 2024/3172 (ITS). In the ITS, the row is not an ‘of which’ row, but an independent row. 2) The row 6.2 (Of which: Retail - Secured by residential real estate) appears to be redundant. Following the ITS instructions for this section, “Where the IRB exposures would have been allocated in a different exposure class in the standardised approach (SA), the IRB exposures shall be excluded from their IRB exposure classes and they shall be disclosed   in one of the following exposure classes of the Standardised approach”. All exposures (partially) secured by real estate must be disclosed on row EU 7a or EU 7c , no exposure can be disclosed on row 6.2, which is an ‘of which’ category of row 6 (Retail). The mapping to COREP C10 row 0170 appears incorrect as it conflicts with the ITS instruction to reclass the exposures.  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7698
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 17/03/2026

Z02.00_r0334 sum of net liability positions taking into account prudential netting rules

In accordance with Articles 429 and 295 of the CRR, only netting agreements that are legally recognised are eligible for consideration under prudential netting rules. With regard to standalone derivative positions that represent liabilities and are not subject to any netting agreement, is it correct to report these in r0334, even though they cannot be netted under the prudential netting framework?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7697
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 13/03/2026

Reverse solicitation

The reverse solicitation is where a client or counterparty approaches an undertaking established in a third country at its own exclusive initiative for the provision of banking services, including their continuation, or banking services closely related to those originally solicited.   A TCB is often invited with an invitation letter sent by one or several commercial banks or investment banks (known as arrangers) in different Member States, to provide loans together with a group of lenders domiciled in various Member States for a borrower or a borrower group that might operate in several Member States. The TCB as a lender does not have direct contact with the borrower. The invitation letter is sent by the arranger bank to invite the TCB to provide a portion of the loan for the borrower. Is the invitation letter sent by the arranger a sufficient supporting document to evidence that a client approaches us through an arranger at its own exclusive initiative? If not, is an independent statement from the borrower to certify that it has approached the TCB through an arranger adequate?   

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7693
  • Topic: Passporting and supervision of branches
  • Date of submission:
  • Published as Rejected Q&A: 17/02/2026

Z08.01 & Z08.02: Resolution resilience reporting

Should the explicit inclusion of clauses referred to in data points c0150 to c0170 of Z08.01-Template and c0100 to c0120 of Z08.02-Template be required only for contracts governed by third-country law, considering that contracts governed by EU law are deemed resolution-resilient by virtue of the implementation of BRRD requirements in the national legislation of Member States?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7690
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 13/03/2026

US Hard test: adequacy of considering US charge-off rates corresponding to loss rates for exposures secured by residential property or commercial immovable property situated within the territory of the US

May institutions in accordance with Article 199 (4a) of Regulation (EU) No 575/2013 (CRR) apply the derogations  from point (b) of paragraph 2 of Article 199 CRR, as referred to in paragraphs 3 and 4 of Article 199 CRR, for residential / commercial immovable property situated within the territory of the US, based on (adjusted) US charge-off rates as published by the Board of Governors of the Federal Reserve System (US), retrieved from FRED, Federal Reserve Bank of St. Louis? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7688
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 27/02/2026

Use of short-term issuer credit assessments under Article 131

May short-term issuer ratings be used to derive risk weights for unrated short-term exposures in the context of Article 131 CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7687
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 26/01/2026

Discrepancies between taxonomy packages

Can you please provide clarity on whether or not the identified differences between ECB's SFRDP taxonomy 5.2 and EBA's FINREP9_DP in DPM 4.2 will be addressed /aligned in a future DPM publication, or if these are intentional and will remain as they are in DPM 4.2? If they will be aligned, please indicate when this can be expected.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7686
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 05/03/2026

Question regarding minimum requirements for Risk Committee attendance

Is there a minimum number of administrators required to be present for a risk committee dedicated to internal control to validly hold its meetings ? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/05 - Guidelines on internal governance under CRD - repealing EBA/GL/2017/11
  • ID: 2026_7685
  • Topic: Internal governance
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2026

Validation rule v5702_s (F 31.01)

We request a change in the status of validation rule number v5702_s from 'Error' to 'Warning' in the consolidated FINREP ITS report. 

  • 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: 2026_7684
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 05/03/2026

Template Z08.01: Validation rules contradict ITS requirements

Do validation rules v6446_m and v6447_m for template Z 08.01 (Relevant services) correctly apply in all reporting situations, given that they enforce the condition {c0030} ≠ {c0050} (Service Recipient must differ from Service Provider)? Should these rules be amended or removed to correctly reflect cases of intra‑entity services, where both fields may legitimately contain the same entity name according to the IT Annex II: Instructions of EBA/ITS/2025/04?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7683
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 03/04/2026

Alternative treatment and SME support factor

If an institution uses the alternative treatment i CRR3 article 230 (4), does the exposure then qualify to use the SME supporting factor?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7682
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/01/2026

Reporting of key values for open sheet tables starting with Z 07.01

We kindly ask for clarification regarding the reporting of key values in case of open sheet tables starting with Z_07.01 for the RESOL2 module. How should the information regarding the location of critical function be reported considering there are two mandatory keys?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7681
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 03/04/2026

Submiting Z06.00 on an individual basis in a separate template for every relevant legal entities (RLEs) in a resolution group

Why every single RLE  in a resolution group should report a separate Z06.00 “Deposit Insurance” template (LIAB 6) at individual level?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7680
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 09/03/2026

Résolution 1 - how liabilities have to be reported on column 0056 of Z11.00

We want to confirm how liabilities have to be reported on column 0056 of Z11.00 ? It is indicated in "Annex II: Instructions": Type of Liability For liabilities which are reported under Z02.00-c0020-Row as “r0210 - Liabilities towards other entities of the resolution group”, indicate the type of liability as it would have been reported in Z02.00, had the liability not been considered as excluded. We would like to know if operations that are not subject to reclassification in line 0210 of Z02.00 will have to be reported ? Indeed, following the final taxonomy, we note that control e7484 from the validation rules indicates that column C0056 "type of liability" must not be null: In Z 11.00, no empty value in columns (c0020, c0021, c0030, c0040, c0045, c0050, c0053, c0055, c0056, c0060, c0080, c0100, c0110, c0120, c0130, c0150) Furthermore, we note that the list of accepted values for column C0056 is extended to all liabilities in Z02 and not just to liabilities reclassified in line 210.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7679
  • Topic: Resolution plans
  • Date of submission:
  • Published as final Q&A: 03/04/2026

ITS (Annex II: Instructions), II.20.4, p. 64 II. 20 Z 08.01— Relevant services (SERV 1) II.8.1; General instructions

We would appreciate a confirmation of the following interpretation: In the context of a group level resolution planning reporting, only services associated with core business lines, whose continuity is necessary for the effective execution of the resolution strategy and any consequent restructuring are reported in Z08.01 of the 2026 Resolution Reporting. Is the understanding correct, that essential services of core business lines which are mapped in Z07.03 only to legal entities that are classified as liquidation entities in the PIA Assessment of the Resolution Authority must not be reported by the Union Parent Undertaking or Resolution Entity on a consolidated basis in Z08.01?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on the provision of information for the purpose of resolution plans
  • ID: 2025_7671
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 03/04/2026

I couldn´t find this question.

We request EBA’s clarification on the application of Article 402 CRR to exposures fully secured by commercial property classified as IPRE under CRR III, but risk‑weighted as non‑IPRE in accordance with the exemption defined in Article 126(2) because the property meets the national conditions applicable in Sweden (the so‑called “hard test”). Specifically: 2.1 Eligibility for Article 402 when collateral is IPRE by classificationDoes the collateral’s IPRE classification affect eligibility for the Article 402 exposure value reduction, specifically for large exposures where the risk-weighting due to the exemption in Article 126(2) is treated as non-IPRE due to national conditions in Sweden (the so-called “hard test”) 2.2 Treatment under Swedish national conditionsIn cases where national authorities allow commercial IPRE collateral to be risk-weighted as non-IPRE under Article 126(2) (Swedish hard test), can the bank apply the Article 402 reduction, assuming all CRM requirements under Articles 399, 208, and 229 are satisfied? In other words: Does Article 402 eligibility follow the risk-weighting treatment under Article 126.2, or does it follow the classification of the collateral under CRR III?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7670
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 13/01/2026