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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.

List of Q&A's

Validation rules taxonomy V4.0 C_08.01.a

Does the validation rule v23372_m should be applied to column 0250?

  • 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

List of IEA Sectors in Column a vs List of IEA Sectors in the EBA3.3 Annotated Table Layout for ESG

The sector named "Chemicals" is listed in the Template 3: Banking book - Climate change transition risk: Alignment metrics, but is missing from the List of NACE sectors to be considered. There is therefore no indication of the NACE codes to consider for Chemicals. The answer to question 2024_7085 confirms that institutions shall also present IEA sector Chemicals as one of the rows for Template 3, but doesn´t tell which NACE sectors are to be used. Which NACE codes should be considered for the sector of Chemicals?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Validation rules taxonomy V4.0 C_10.00

The formulae seems irrelevant

  • 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

Validation rules taxonomy V4.0 C_10.00

The formulae of the control seems irrelevant

  • 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

Validation rules taxonomy V4.0 C_10.00

The formulae of the control seems irrelevant

  • 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

Validation rules taxonomy V4.0 C_10.00

The formuale of the control seems irrelevant

  • 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

Validation rules taxonomy V4.0 C_10.00

The formulae of the control v23054_m seems irrelevant

  • 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

Validation rules taxonomy V4.0 C_10.00

The formulae of the control v23053_m seems irrelevant

  • 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

Validation rules taxonomy V4.0 C_10.00

The formulae of the control v23052_m seems incoherent

  • 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

Validation rules taxonomy V4.0 C_08.01.a,C_08.02,C_09.02

The EBA Validation rules taxonomy v7551_m seems not relevant.

  • 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

Validation rules taxonomy V4.0 C_08.01.a,C_08.02,C_09.02

The EBA Validation rules taxonomy v7549_m seems not relevant.

  • 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

Validation rules taxonomy V4.0 C08.01/C08.02

The EBA Validation rules taxonomy v10667_m seems not relevant.

  • 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

Validation rules taxonomy V4.0 C08.01/C08.02

The EBA Validation rules taxonomy v10666_m seems not relevant.

  • 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

Validation rules taxonomy V4.0 C08.01/C08.02

The EBA Validation rules taxonomy v10664_h seems not relevant.

  • 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

Interpretation of the treatment of covered bonds under the large exposures' regime in accordance with Article 395 of the CRR and the possibility of exposure reduction pursuant to Article 399 of the CRR.

Can covered bonds used as collateral in repo transactions, which are issued by the borrower (self-issued covered bonds), be considered eligible for exposure reduction under the large exposures regime in accordance with Article 399 of the CRR, taking into account the current interpretation of Article 207(2) of the CRR and Article 400(2) of the CRR, as well as the application of ECB Regulation (EU) 2016/445?

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

DPM 4.0 - Correctness of identical cells for C 08.01.c

For DPM 4.0 the cells {C_08.01.c, r0070, c0130, s*} and {C_08.01.c, r0180, c0130, s*} are identified as identical and have the same VariableID. Considering the instructions for reporting the data in rows 0070 and 0180 different values are expected.

  • 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

Can a receivable be identified as IPRE if a mortgage exists, but the securing property is not recognised as collateral?

Art. 124 para. 1 stipulates that banks receive a risk weight of 150% for IPRE receivables that do not fulfil all the conditions set out in para. 3. The question is what constellation of conditions must be met for this case to realistically materialise. An institution should normally be able to fulfil subsections a to d in para. 3. Paragraph 3 contains a reference to Article 208 and paragraph 1 of Article 229 in sub-item e. Article 229 paragraph 1 describes the property valuation and will not generally present institutions with insurmountable problems either. Article 208 begins with the statement that a property is only recognised as collateral if the following paragraphs 2 to 5 are fulfilled. One hurdle could possibly be the monitoring of the property value in accordance with paragraph 3. However, it is also conceivable that an institution will generally refrain from recognising real estate collateral due to an insignificant share in the portfolio. Can a receivable that is effectively secured by a mortgage be identified as an IRPE risk position without recognised real estate collateral, resulting in an RW of 150% under Art. 124 para. 1? Or does non-recognition also mean that the exposure is not to be regarded as collateralised (by a property) for the calculation of own funds and consequently receives the risk weight of an unsecured exposure?

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

Taxonomy 4.0: The validation rules v7538_m and v7546_m perform consistent cross-checks?

In terms of Implementing Technical Standards (ITS), when checking the rules of the COREP_OF module for Tables C_08.01.a, C_08.02, C_09.02 have been detected inconsistencies in the validation rules under template C09.02 cross check part. It’s possible to verify this?

  • 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 standardised total risk exposure amount or S-TREA under Article 92(25)

Does the calculation of standardised total risk exposure amount, or S-TREA, require Firms to recalculate RWAs for standardised approaches where modelled inputs have been used? Specifically, do CVA RWAs calculated using IMM modelled EADs need to be re-calculated using EADs that have not been derived using a modelled approach?

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

Appropriate CR SA sub-exposure class categorisation (line items reported within C02.00, C07.00 and C09.01, where applicable) of the portion of an exposure “secured by mortgages on immovable property” which is also secured by cash or subject to other form of credit protection such as eligible guarantees.

Some of the exposures “secured by mortgages on immovable property” existing on an institution’s loan book are also secured by other forms of credit protection, such as cash or eligible guarantees. For such exposures, it is not clear as to which sub-exposure class such portion of the exposure (e.g. the cash-secured portion) shall be attributed.   For example, assume that an institution has a non-IPRE exposure (loan to natural person) secured by residential immovable property, which is also partially secured by cash. To which of the following sub-exposure classes will the portion of the exposure that is secured by cash collateral be classified?  (i)    Secured by mortgages on residential immovable property - non-IPRE (secured) - C09.01, r0091; C02.00, r0151(ii)   Secured by mortgages on residential immovable property - non-IPRE (unsecured) - C09.01, r0092; C02.00, r0152(iii)  Secured by mortgages on residential immovable property - Other - non-IPRE - C09.01, r0093; C02.00, r0153  NB: Please also affirm that in the referenced example (i.e. retail counterparty), the Original exposure pre-conversion factors related to such cash-secured portion shall be equivalent to a risk weight of 75% in line with Art 124(1)(a), which is subsequently reduced to 0% through the reporting of CRM techniques with substitution effect via the “Other Items” exposure class (under the financial collateral simple method), in line with the principle applied in EBA Q&A 2016_2693.   In the quoted example, we understand that such portion shall be reported as “Secured by mortgages on residential immovable property - Other - non-IPRE”.

  • 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