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

FMI Reporting

In defining field 0040 (System type) in the latest hotfix to EBA DPM 4.2 (January 14th), EBA did not include value eba_qMA:qx2046 Payment Systems in the list of accepted values in the Annotated Template Layout

  • 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_7723
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Assigning risk-weight to a credit facility where the drawdown is contingent on non-credit risk related conditions that are required to be met by the obligor prior to any initial or subsequent drawdown and where the conditions for the drawdown are not met.

What risk-weight should be assigned to a credit facility where the drawdown is contingent on non-credit risk related conditions that are required to be met by the obligor prior to any initial or subsequent drawdown and where the conditions for the drawdowns are not met per the reporting date?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7722
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 13/03/2026

Z 09.01 FMI 1 - System type enumerated property

A clarification is needed regarding which option in the enumerated list used in the DPM for column 0040 of Z 09.01 should be selected to report the system type ‘Payment systems

  • 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_7721
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Inconsistencies Between ITS Templates and DPM 4.2 Annotated Table Layouts for RESOL 1/2

When inconsistencies exist between the ITS templates and the DPM 4.2 Annotated Table Layouts, which source should be considered authoritative for reporting purposes?

  • 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_7720
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Net liquidity outflows over a 30 calendar day stress period

If a facility agreement includes a condition that causes a committed revolving facility to become non‑revolving during a period of stress for the credit institution, should the net liquidity outflow for LCR purposes then be calculated based on the maturity date of each individual drawing rather than the overall facility maturity date?

  • 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: 2026_7719
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 31/03/2026

Dropdown lists are invalid

Dear Sir/Madam  We have noticed that in the templates published by the EBA, the name manager reference for templates containing dropdown fields shows a #REF! error, causing the dropdown lists to be invalid. If possible, could you please provide us with the correct version of the template?  Kind Regards

  • 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_7718
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 27/02/2026

LCR treatment of issuances with automatic optionality/knock-out features

What is the LCR treatment of issuances with automatic optionality/knock-out features (hereinafter: ‘auto-callable issuances’) whereby notes are automatically redeemed should the underlier meet a strike level on specified observation dates?

  • 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: 2026_7716
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 24/04/2026

EBA RESOLUTION TEMPLATE Z09.02 ON FINANCIAL MARKETS INFRASTRUCTURES

We need additional guidance in Z0902 on how to report FMIs related to Core Business Lines only, or FMIs related to more than a single Core Business Line. We kindly ask your guidance on how to report the following use cases: A purely Essential FMI, that is an FMI not linked to any Critical Economic Function (hence, with 0060 set to empty), but linked to one Core Business Line; An FMI that needs to be linked to more than one Core Business Line (hence, where we would need to insert several distinct values in 0060)

  • 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_7713
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

Treating lease exposures as collateralised under the F-IRB approach

Is a permission of the competent authority under Article 199(6) of the CRR required for treating lease exposures as collateralised under the F-IRB approach if the lease object corresponds to other physical collateral?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7712
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/05/2026

Deduction of goodwill included in the valuation of significant investments in entities included in prudential consolidation

For the purposes of calculating own funds on an individual basis and a sub-consolidated basis, are institutions subject to supervision on a consolidated basis required to deduct goodwill included in the valuation of significant investments of the institution, for holdings in such entities that are included in the scope of consolidated supervision?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7709
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 27/02/2026

Z 07.02 - Mapping of economic functions to legal entities (FUNC 2)

We request confirmation that in the Z 07.02 only the contribution of legal entities to the Group critical functions  should be reported in the template, and not their contribution to all economic functions considering that in the Annotated Table the key value is represented by the column 0020 ID - Critical function (CF to LE) .

  • 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_7707
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 30/04/2026

Z 01.02 - Ownership structure (ORG 2)

The template require to report all the shareholders (or equivalent) of the group’s entities with more than 2% of share capital (or equivalent) or voting rights, and all the shareholdings (or equivalent) held by entities of the group. In the annotated table for the Z_01.02, the key value is represented only by the column 0020 “Code”. In the event that the same investor holds shares in multiple entities of the Group, it is not possible to report all the shares as an investor can only be reported once.

  • 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_7706
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/04/2026

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

DPM 4.2 on SERV Template (Z.08.04)

We are writing to request a clarification regarding the latest DPM update dated 13 January, with specific reference to Template Z8.04.In the current version, the “Critical Function - ID” field (column 0040) is not included among the key fields. However, in Template Z8.05, the “Business Line ID” is defined as a key field.This difference creates a reporting challenge for us. A single service, identified by a unique Service Identifier, may support more than one critical function. If the “Critical Function” field is not part of the key, it is not possible to link multiple critical functions to the same service within the template.As a result, we would need to create multiple Service Identifiers for the same service, leading to an increased number of records across other templates, including Template Z8.01.Could you please confirm whether the exclusion of the “Critical Function - ID” from the key fields in Template Z8.04 reflects the intended approach?

  • 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_7703
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 30/04/2026

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