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

Deferred tax assets related tax loss due to losses on derivatives in cash flow hedge accounting relationships

In accordance with Article 33(1)(a) CRR, institutions do not include fair value reserves related to gains or losses on cash flow hedges in own funds. Is it correct to also filter deferred tax assets related to the tax loss resulted from fair value reserves related to gains or losses on cash flow hedges?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6831
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 16/08/2023

Clarification on EBA provisions for treatment of Non-Stable and Non-Core NMDs in SOT on NII.

Can banks, in their internal measurement methodologies for calculating the NII SOT baseline scenario, for renewed Non-Stable/Non-Core NMDs assume repricing at the current market interest rate without any commercial margin, in order to avoid stabilisation of NII on unstable funds? Is this approach in line with EBA/GL/2022/14 and permitted under EBA/RTS/2022/10?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2022/14 - Guidelines on interest rate risk arising from non-trading book activities
  • ID: 2023_6830
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 15/02/2024

jiol;ikoio

yhikhujkjh

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2023_6829
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 20/07/2023

Definition of ‘turnover’ for the purposes of Country-by-Country reporting

What should be considered as ‘turnover’ for the purposes of country-by-country reporting in Article 89(1) of Directive 2013/36/EU (CRD) in light of amended Accounting directive?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6828
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 15/03/2024

Trusted Beneficiaries

Please clarify whether under Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication (hereinafter: RTS on SCA & CSC) is it allowed to use the same SCA element to authorize a payment and at the same time (using the same session ID) approve (technically using by a checkbox) the payee as a trusted beneficiary? If it is allowed, the payment service user (hereinafter: PSU) shall be informed (prior to authorisation) by an approval SCA element (SMS) about the payment execution and about modifying the list of the trusted beneficiaries as well?

  • 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: 2023_6827
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 29/09/2023

Exposure excluded from total exposure measure for the calculation of the leverage ratio

Can the assets that represent funds deposited by a payment institution with the institution, for the fulfilment of its safeguarding obligation under directive 2015/2366 on payment services, be assigned with a risk weight of 0% to the extent they are placed by the institution with a central bank and consequently be excluded from the total exposure measure in accordance with article 429a (1) (c)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6826
  • Topic: Leverage ratio
  • Date of submission:
  • Published as Rejected Q&A: 16/08/2023

Template F 16.01 validation rule v5693_s

Is it possible to report negative income from General Government debt securities in F 16?

  • 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
  • ID: 2023_6825
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 15/03/2024

ALMM - C 70.00 : Report of weekends in template C70

Should entities leave empty weekends and holidays in column ‘Overnight’ even when they have information on current accounts for those days?

  • 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
  • ID: 2023_6824
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 01/11/2023

Transfers to PPE

We have a collateral obtained some years back that was classified as Commercial Immovable property. In the current year the Group decided to transfer this property to PPE and use it for its own branches.  In table 25.1 the below rows exist. Where can we put the transfer (therefore outflow) mentioned above? Outflow for which cash was collected Outflow with replacement by financial instrument Outflow due to negative changes in value

  • 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
  • ID: 2023_6823
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 06/10/2023

Template C 14.00 column 0287 & Template C 14.01, column 0362

Pursuant to Template C 14.00 (column 0287) and Template C 14.01 (column 0362) of the Regulation (EU) 2021/451 (Version: Reporting Framework 3.2) the synthetic excess spread (SES) should be reported under the section “off-balance sheet items and derivatives”. Does this indicate that all synthetic securitisations have to be reported under “off-balance sheet items and derivatives”? More specifically, does the balance sheet treatment of the securitisation positions in columns 0310 – 0400 refer to the securitisation position itself (i.e. all the columns must be either on-balance or off-balance (e.g. off-balance in case of a CDS)) or to the underlying (i.e. the underlying loans must be reported as on-balance and the synthetic excess spread as off-balance; the result is that in the same row (corresponding to one securitisation position) different columns are reported which can refer to both on- and off-balance positions))? E.g.: An institution acts as originator in a direct synthetic securitisation of loans. There are three tranches (junior, mezzanine, senior) and a synthetic excess spread. Significant risk transfer is achieved. The underlying exposures remain on the balance sheet of the originator.

  • 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
  • ID: 2023_6822
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:

ESG P3 - NACE sector breakdown in Pilar III reporting (templates 1 and 5 and, partially 3)

Should NACE activity codes be consistent between FINREP and Pilar III ESG reporting, or can P3 ESG templates breakdowns be adjusted to differ from FINREP but better align with sustainability linked info?   

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2023_6821
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 09/10/2023

Exemption from strong customer authentication

Do the revisions to Art.10 set out in Commission Delegated Regulation (EU) 2022/2360 of 3 August 2022 amending the regulatory technical standards laid down in Delegated Regulation (EU) 2018/389 as regards the 90-day exemption for account access mean that a payment service user or account information service provider is now limited to accessing only the account balance OR the transaction details for the last 90 days when availing of the revised exemption?

  • 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: 2023_6820
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 29/09/2023

Aggregation of P&L for Net Interest Income

In Article 22 of draft EBA/RTS/2022/10, it stated to apply 50% to profit when aggregating P&L at currency to get total NII.  If the stress NII at currency level are all profits (as seen in our calculation under +shocks scenario), do I apply 50% to each profit, or profit in one currency should be allowed 100% (if so, should it be the reporting currency, or any chozen currency)? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6819
  • Topic: Accounting and auditing
  • Date of submission:
  • Published as Rejected Q&A: 05/09/2023

Calculation of the NPL ratio for determining F_23.00 to F_26.00 reporting requirements

In calculating the ratio outlined in Article 11(g)(ii) of the ITS on Supervisory Reporting to determine applicability of reporting requirements for F_23.00 to F_26.00, should institutions exclude cash balances at central banks and other demand deposits from both numerator and denominator?

  • 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
  • ID: 2023_6818
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 22/07/2023

Prudent Valuation: Reporting of AVAs in C 32.03

How should the AVAs of model risk be reported in the template C 32.03. Can the Fair Value Adjustments linked to Model Risk, Model Risk UCS y Model Risk I&FC AVAs be included into the C 32.03?

  • 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
  • ID: 2023_6817
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 13/10/2023

Treatment of corporate debt securities issued by entities that are set up to raise financing for the parent company or group in the LCR liquid asset buffer

Can corporate debt securities that are issued by entities that are set up to raise financing for the parent company or group be included in the LCR liquid asset buffer, considering that that the main business of this specific entity within the group is the participation of securities issues, which is one of the activities listed in Annex I to Directive 2013/36/EU?

  • 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: 2023_6816
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 16/08/2023

Calculation of expected credit losses for guaranteed exposures

We would like to know whether full substitution of the guarantor parameters to the debtor’s parameters (so that ECL are effectively calculated on the guarantor) can take place when calculating ECL on a guaranteed exposure in accordance with Regulation 2016/2067 (IFRS 9) as elaborated on by EBA Guidelines 2017/06.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6815
  • Topic: Accounting and auditing
  • Date of submission:
  • Published as Rejected Q&A: 16/08/2023

v11962_m;v11963_m; v11964_m; v11965_m; v11966_m; v11967_m; v11968_m; v11969_m; v11970_m; v11971_m; v11972_m; v11973_m; v11974_m; v11975_m; v11976_m; v11977_m; v11978_m; v11979_m; v11980_m; v11981_m; v11982_m; v11983_m; v11984_m; v11985_m; v11986_m; v11987_m; v11988_m; v11989_m; v11990_m; v11991_m; v11992_m; v11993_m; v11994_m; v11995_m; v11996_m; v11997_m; v11998_m; v11999_m; v12000_m; v12001_m; v12002_m; v12003_m; v12004_m; v12005_m; v12006_m; v12007_m; v12008_m; v12009_m; v12010_m; v12011_m; v12012_m; v12013_m; v12014_m;

Why there is still some validation rules which control if Financial Garantee and Collateral are less than the Gross Carrying Amount in FINREP 19.00?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6814
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 22/07/2023

EBA VR v7872_m; v7873_m; v7874_m; v7875_m; v7876_m; v7877_m

Why there is still some validation rules which control if Financial Garantee and Collateral are less than the Gross Carrying Amount in FINREP 18.02?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6813
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 22/07/2023

Impacts on Consolidated Group LCR Deposit Categorisation where a Third Country subsidiary utilises a different threshold

As per Article 3 of the LCR Delegated Act, SME deposits are classified as Retail if their balance is <=€1m threshold. Additionally, Article 25 paragraph 2 defines a €500k threshold criteria for Other Retail Deposits. The national law within the UK has specified these thresholds as £880k and £440k respectively.  We would like to confirm if within the consolidated Group return, the outflow weighting should be applied based on the third country subsidiary regulatory definition or applied based on the LCR Delegated Act definition when converted into the Group’s reporting currency?

  • 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: 2023_6812
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 14/09/2023