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List of Q&A's

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
  • ID: 2025_7385
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 23/05/2025

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
  • ID: 2025_7384
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 23/05/2025

AIRB combined with Financial Collateral Comprehensive Method

Article 223 para 4 subpara (b) indicates that banks using the A-IRB approach can also utilize the Financial Collateral Comprehensive Method (FCCM). Does the EBA agree with this?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7382
  • Topic: Credit risk
  • Date of submission:

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
  • ID: 2025_7381
  • Topic: Financial conglomerates
  • Date of submission:
  • Published as final Q&A: 11/07/2025

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
  • ID: 2025_7380
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 23/05/2025

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)
  • ID: 2025_7379
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 22/05/2025

Identical Cell Template C 10.00

Can you confirm that the definition of these cells as identical cells is 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_7378
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

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
  • ID: 2025_7377
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 23/05/2025

the use of strong and widely recognized encryption techniques

All strong and widely recognized encryption techniques (e.g. RSA and ECC) currently available on the market must be provided by the account servicing payment service providers or only that encryption technique which is indicated in the documentation of the technical specification of the API in accordance with Article 30(3) of the RTS on SCA & CSC shall be provided?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2025_7376
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:

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
  • ID: 2025_7375
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 27/03/2025

Reporting of the Application of Article 465(5) of CRR in template C 10.00

Could EBA provide guidance on whether institutions that do not apply the transitional arrangements set out in Article 465(5) of CRR can leave the rows 0151 and 0152 ‘of which: exposures secured by mortgages on residential property up to 55% of the property value’ and ‘of which: exposures secured by mortgages on residential property between the 55% and 80% of the property value’ empty in template C 10.00?  

  • 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
  • ID: 2025_7374
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 13/06/2025

Whether to Include in the Scope of C 10.00 Portion of IRB Exposures that are guaranteed by Guarantors that are to be treated under SA

Could EBA provide guidance on whether to present in template C 10.00 the portion of an IRB treated exposure that has been secured by an eligible guarantee which becomes an SA treated exposure as a result of a CRM/substitution effects?  

  • 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_7373
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:

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
  • ID: 2025_7371
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 23/05/2025

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
  • ID: 2025_7370
  • Topic: Financial conglomerates
  • Date of submission:
  • Published as Rejected Q&A: 28/04/2025

Exist a definition of information security standards

In DORA Article 28 (5), reference is made to "appropriate information security standards" and "of the most up-to-date and highest quality information security standards". Is There a definition of which standards are applicable here, or can credit institutions define the desired requirements themselves?"

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7369
  • Topic: ICT third-party risk management
  • Date of submission:
  • Published as Rejected Q&A: 25/06/2025

Calculation of Kirb

According to Article 255(2)(3), Kirb seems to be defined as (EL+UL)*8%/exposure value of the underlying pool. However, considering the fact that, for unexpected loss, banks hold an amount of regulatory capital by UL*8%, but for expected loss not covered by provisions, banks have to deduct it from Tier 1 capital,  As Kirb stands for the averaged capital requirement of the underlying exposures(including expected loss), it should be calculated as (UL*8%+EL)/exposure value of the underlying pool instead.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7368
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as Rejected Q&A: 01/09/2025

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
  • ID: 2025_7367
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as Rejected Q&A: 23/07/2025

Definition of financial counterpart

Can you confirm whether our interpretation of the notion of ‘financial counterpart’ is correct?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7366
  • Topic: ICT-related incidents (management / classification / reporting)
  • Date of submission:
  • Published as Rejected Q&A: 25/06/2025

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
  • ID: 2025_7365
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 25/03/2025

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
  • ID: 2025_7364
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 23/05/2025