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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

Use of Turnover taxonomy eligibility/alignment or Capex taxonomy eligibility/alignment for Pillar 3 Risks ESG disclosures

Question 1: We interpret that the wording "general purpose lending part" excludes “specialised lending” and it leaves the door open to derive that Capex may be used for specialised lending and/or when the use of proceeds is known. Could you please indicate if for some of the Pillar 3 reports the Capex taxonomy eligibility/alignment should be used instead of the turnover taxonomy eligibility/alignment. If yes, may you please precise under which conditions Capex taxonomy eligibility/alignment should be used and to which report it applies and potentially to which columns/rows if relevant. Question 2: Is there any intentional distinction between the wording “use of proceeds is known” versus the wording “specialised lending”? If yes, could you explain the difference?

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

F 46 EBA_v1226

How to match the re-translated opening balance (in current year) with closing balance (from prior year) on F 46 when the constant USD value is being converted to EURO in two different reporting periods with different FX rate? If the same prior year converted value in EURO is stated in opening balance (before restatement row 10), then how and which row does the FX translation impact shall be reflected?  

  • 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

Article 111 or about

What CCF and provisions should be allocated, if any, in year 1/2/3/4 considering this special situation that I cannot find in the regulation?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2019/01 - Guidelines on specification of types of exposures to be associated with high risk under Article 128(3) of CRR

Clarification of the definition for "residence"

In the template FIN 20.4, we need to restitute engagement under a geographical breakdown by residence of a counterparty. Immediate counterparty is clearly defined in the annex 5 but the definition of residence is not detailled. Could you give us a more detailed definition for the residence to use for the production of data into this template?

  • 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

Multiple collaterals reporting for Pillar 3 ESG risks disclosure, Template 2 and 5

In case a loan has multiple collaterals (of which immovable property and also other collateral types) should the entire gross carrying amount be reported as collateralised by the immovable property or should the amount be pro-rated?

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

NACE codes for the sectors that highly contribute to climate change for Pillar 3 ESG risks disclosure, Template 1

Included in the template’s rows of the Sectors that highly contribute to climate change we find also Sector I (Accommodation and food service activities) in row 51, while in the instructions and in the Commission Delegated Regulation it’s clearly stated that such sectors include only NACE Sectors A to H and L. Is it a typo, or else what is the reason behind this? 

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

Maturity reporting for Pillar 3 ESG risks disclosure, Template 1 and 5

How should we treat products without stated maturity (such as on demand, equity, perpetual loans) in the maturity buckets and in the average weighted maturity computation? E.g. perpetual loans will probably end up in the >20 years bucket, but which year should we use for the computation of the average weighted maturity? Or Equity holdings are mentioned in the instructions, but it's not clear in which maturity bucket we should report them and which year to use for the computation of the average weighted maturity.  

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

Residential Immovable Property

Paragraph of ANNEX XL - Instructions for disclosure of ESG risks states that "Institutions shall include in this template information on exposures in the banking book (including loans and advances, debt securities and equity instruments not held-for-trading and not held-for-sale), towards non-financial corporates, on loans collateralized with immovable property and on repossessed real estate collaterals, exposed to chronic and acute climate-related hazards, with a breakdown by sector of economic activity (NACE classification) and by geography of location of the activity of the counterparty or of the collateral, for those sectors and geographical areas subject to climate change acute and chronic events." It is not entirely clear to us if retail residential mortgages are in scope of template 5 for Physical Risk Discjosures? or if only loans towards NFCs shoudl be taken into account? 

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

Scope of templates C 08.05 and C 08.05.1

What is the criterion that an exposure class must meet to be included in template C 08.05.1 (“Credit risk and free deliveries: IRB approach to capital requirements: back-testing of PD”)? Should the exposures included in that template be complementary of those included in template C 08.05 (“Credit risk and free deliveries: IRB approach to capital requirements: back-testing of PD”) or should an extra detail be provided for certain categories? From the point of view of Pillar 3 disclosures, the same question applies to tables EU CR9.1 and EU CR.9 respectively, as they replicate the content and structure of the mentioned reporting templates.

  • 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

Scope of the C 08.07 template

Where a group as defined in Article 4 of CRR has both SA and IRB exposures, what should be the scope of the total exposure value subject to SA and IRB as defined on column 0020 of template C 08.07 - Credit risk and free deliveries: IRB approach to Capital Requirements (Scope of use of IRB and SA approaches)? Should the scope only include entities consolidated within the group with permission to use the IRB approach, or should it include all entities consolidated within the Group, even those with no permission to use IRB approach and no IRB exposures?

  • 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

v6566_s - Negative FV changes of hedged items (C 32.01)

How should negative fair value changes of the hedged items in portfolio hedge of interest rate risk be reported in the context of the prudent valuation templates in COREP (C 32.01)?

  • 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

Template 10: other climate change mitigating actions

Should template 10 include exposures to counterparties not included in GAR e.g., exposures to be included in BTAR (template 9) or exposures that is either taxonomy eligible or aligned?

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

Template 10: Other climate change mitigating actions - Repurchases double counting

How do we avoid double counting if we invest in our own covered bonds? Both the loan and the covered bond will be in Template 10.

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

Template 10: Other climate change mitigating actions - Covered bonds

Is it correct that a covered bond will be classified as a bond with a credit institution (financial corporation) as counterparty?

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

Template 5: climate change physical risk

What is meant by “other relevant sectors” - could it be a sub sector of the sectors in row 1 to 9?

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

Template 2: banking book - climate change transition risk

Is column “p” to include the share of gross carrying amount without EPC label, for which there is data on the actual energy consumption from measured consumption in the real estate?

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

Template 2: banking book - climate change transition risk

Is it allowed to use more precise information about the energy consumption of the collateral (i.e. primary data on actual building energy consumption) instead of the consumption indicated in the EPC label?

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

C 34.06 – Top twenty counterparties

In the COREP Own Funds reporting template C 34.06 the top 20 counterparties ranked by CCR exposure shall be shown. If a counterparty acts both as QCCP and as Non-QCCP/bilateral counterparty, should the counterparty be listed twice in the template or only once with the higher exposure?

  • 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

Template 1: banking book (prudential disclosures on ESG risks)

Is EBA aware of any data providers that have information of the companies excluded from the EU Paris-aligned Benchmarks in accordance with points (d) to (g) of Article 12.1 and in accordance with Article 12.2 of Climate Benchmark Standards Regulation or are the companies required to publish that kind of information under other EU legislation?

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

Template 1: banking book (prudential disclosures on ESG risks)

Are you obliged to use the NACE code sector of the specific obligor under the holding company (template 1, point 8 on page 10 in Annex XL)?

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