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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

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

Calculation of risk-weighted exposure amounts for off-balance exposure in case of Unfunded Credit Protection (UFCP)

What is the correct treatment in cases where the consideration of CRM according to articles 235, 235a or 236 leads to higher calculated risk-weighted exposure amounts than those calculated without considering CRM, even when the risk weight of the protection provider is lower? 

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

Calculation of risk weights

How should institutions calculate a risk weight amended for credit protection in accordance with Chapter 4?

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

Validation rules taxonomy V4.0 C10.00 v23057_m

Does formulae v23057_m should apply to all columns?

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

Validation rules taxonomy V4.0 C10.00 v23055_m

Does formulae v23055_m should apply on all columns?

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

Validation rules taxonomy V4.0 C10.00 v23054_m

According to the formulae v23054_h : {r0150} >= {r0151} in C10.00.This control indicates that the row r0150 “Secured by mortgages on immovable property and ADC exposures” must be superior to row r0151 “  Of which: Exposures secured by mortgages on residential property up to 55% of the property value” on all report rows.However, the formula of control v23086_m indicates that only row r151 must be reported on memo item column c0090 "EXPOSURES SECURED BY MORTGAGES ON RESIDENTIAL PROPERTY UP TO 55% OF THE PROPERTY VALUE" so the first control cannot be compliant as row r150 must be empty. This also applies to rows r150 and r151 on memo item columns c0100, c0110 and c0120 as formulae v23087_m and v23088_m indicate that, respectively, only rows r0152 and r0101 should be reported on, respectively, columns c0100 and c0110.Could you please therefore confirm that the control v23054_m needs to be modified and should apply to all columns except memo items columns?

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

COREP_OF, C_07.00, problem with disallowed risk weight 70%

Why are cells r0210-c0010, r0210-c0030, and r0210-c0040 (Risk Weight 70%) in table C_07.00 disallowed despite CRR3 Article 126 allowing a 70% risk weight for certain exposures (ETV ≤ 60%)?

  • 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

COREP_OF, C_07.00, problem with disallowed risk weight 70%

Why are cells r0210-c0010, r0210-c0030, and r0210-c0040 (Risk Weight 70%) in table C_07.00 disallowed despite CRR3 Article 126 allowing a 70% risk weight for certain exposures (ETV ≤ 60%)?

  • 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 the SME supporting factor for off-balance-sheet exposures

Is the SME supporting factor applicable, and if so, how shall it be computed, in case there is no on-balance-sheet exposure to be included in E*, as defined in Article 501(1) of CRR?

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

Prudential treatment of goodwill and other intangible assets arising from the acquisition of an asset manager by an insurance undertaking fully owned by a bank

For the purposes of a deduction under Articles 36(1)(b) and 37 of the CRR, should a bank, which owns 100% of an insurance undertaking which acquires a controlling shareholding in an asset manager, deduct goodwill and other intangible assets (Article 4(1)(113) and (115) of the CRR) generated by the acquisition carried out by its insurance undertaking subsidiary?

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

breakdown of total exposures by risk weights

How should exposures subject to a risk weight of 70% according to Art. 126 (2) CRR3 be reported in the ITS on supervisory reporting v4.0? Should these exposures be included in the row r0280 “other risk weights” of the template C 07.00?

  • 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

DPM 4.0 taxonomy, several validation rules are not correct

During the analysis of DPM 4.0 taxonomy, we identified the following issues in the validation rules: EBA validation rule, v23083_m (C25.01) Current rule: with {tC_25.01.a, (c0010, c0020, c0050, c0060, c0070, c0090, c0100, c0110, c0140, c0150, c0160, c0170, c0180, c0200, c0210, c0220, c0230, c0240, c0250, c0270, c0280, c0290), default: 0, interval: true}: {r0040} = {r0050} + {r0060} + {r0090} + {r0100} + {r0110} Proposal: the rule should be deactivated Reason: CVA-risk amounts can be non-additive due to portfolio effects   EBA validation rule, v23345_s  (C25.01) Current rule: with {tC_25.01.a, default:null, interval:false}: {(r0010, r0020, r0030, r0040, r0050, r0060, r0070, r0080, r0090, r0100, r0110, r0130), (c0010, c0020, c0060, c0100, c0110, c0140, c0150, c0160, c0170, c0180, c0200, c0210, c0220, c0230, c0240, c0250, c0270, c0280, c0290)} >= 0 Our Proposal: the rule should be deactivated Reason: Marginal CVA-risk amounts can be negative due to portfolio effects   EBA validation rule, v23710_s  (C25.01) Current rule: with {tC_25.01.a, default: null, interval: false}: {(r0010, r0020, r0030, r0040, r0050, r0060, r0070, r0080, r0090, r0100, r0110, r0130, r0230, r0240), (c0070, c0090)} >= 0 Our Proposal: the rule should be deactivated Reason: Marginal CVA-risk amounts can be negative due to portfolio effects   Mapping Pillar 3 disclosures templates with supervisory reporting (Template EU CMS2. Column d) Column d (RWEAs calculated using full standardised approach) shows the relevant Output-Floor S-TREA without Floor transitional rules according to CRR Article  465 (3) – (13). It is calculated as a surcharge of the current Output Floor S-TREA. But the values from Template C10.00  for transitional rules regarding  EXPOSURES SECURED BY MORTGAGES ON RESIDENTIAL PROPERTY are missing and must be included analogous to template EU CMS1 (à there: {C10.00, r0010, c0090} + {C10.00, r0010, c0100}).    EBA Validation rule v1659_m (C07.00) Current rule: {c0200} = {c0150} - {c0160} - ( 0.90 * {c0165}) - ( 0.8 * {c0170}) - ( 0.6 * {c0175}) - ( 0.5 * {c0180} - {c0195}) Proposal: {c0200} = {c0150} - {c0160} - ( 0.90 * {c0165}) - ( 0.8 * {c0170}) - ( 0.6 * {c0175}) - ( 0.5 * {c0180}) - {c0195} Reason: the term  {c0195} should be excluded from the 0.5-weight-bracket, because UCCs have under the transitional arrangement a 0% CCF and must be subtracted completely.   EBA Validation rule v6052_m (C 09.02) Current rule: {r0150} = {r0010} + {r0011} + {r0012} + {r0013} +{r0020} + {r0030} + {r0060} + {r0132} +{r0140} Proposal: {r0150} = {r0010} + {r0012} + {r0013} +{r0020} + {r0030} + {r0060} + {r0132} +{r0140} Reason: the "of which" position should not be part of the sum. 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)

Presentation of fully matured loans and deposits in templates F05.01 and F08.01

Could you please clarify how fully matured loans and deposits should be presented in templates F05.01 and F08.01?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)

Treatment of Net Interest Income Stress Outlier Test (NII SOT) in scenarios where breaches occur due to one-off effects (EBA/RTS/2022/10)

Could you please provide guidance on how banks should approach the reporting of such NII SOT breaches arising from such short-term, non-structural events and in addition how is it foreseen that the regulator should govern such cases? Specifically, are there any provisions or considerations that can be applied to account for these temporary effects without misrepresenting the bank's overall NII sensitivity? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 530/2014 - RTS on materiality of thresholds for internal approaches to specific risk in the trading book

Counterparty classification

On FINREP reports, each counterparty is classified into a counterparty type, like Household or Government. Some government services are provided by volunteers, which raises the question how this should be classified, since the people are technically not employed by the government. Examples include volunteer police or volunteer firefighters and their unions, whose members provide and/or facilitate services specific to governments.

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

Validation rule v8821_m

The validation rule defines that in the event that column 020 of the template is valorised with the identification code indicating LEI code (eba_qCO:qx2000) then column 030 must be valorised with a LEI code.In reality, column 020 indicates the type of code to identify the third-party ICT service provider indicated in column 010. Consequently, shouldn't the validation rule be correct that the check should be made on column 010 and not 030?  

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

v16319_s and v16322_s (IRRBB) – non-negative rule not applicable to derivative rows

In line with the de-activation of v22331_s, we request to de-activate v16319_s and v16322_s as well

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

Template EU MR4 missing from Annex

The EBA Pillar 3 mapping tool mentions template EU MR4. I cannot find this in any of the annexes. Is this template relevant?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/11 - Guidelines on disclosure requirements under Part Eight of CRR

Definition of ‘subordinated liabilities’ for FINREP reporting

What should be considered as ‘subordinated liabilities’’ for financial reporting purposes in FINREP template 8.2? Does definition of “subordinated liabilities” include also MREL instruments that do not qualify as Common Equity Tier 1, Additional Tier 1 or Tier 2 items meaning and have characteristics defined in the Article 72b(2) of 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