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

Incoherent formulae of the validation rule v90317_m

The control formula currently in place for column 0070 / row 0340 of template C16.02 does not seem aligned with your definition of this indicator. Could you clarify the expected logic?

  • 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: 2026_7862
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

Incoherent formulae of the validation rule v90316_m

The control formula currently in place for column 0070 / row 0310 of template C16.02 does not seem aligned with your definition of this indicator. Could you clarify the expected logic?

  • 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: 2026_7861
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

Incoherent formulae of the validation rule v90315_m

The control formula currently in place for column 0070 / row 0260 of template C16.02 does not seem aligned with your definition of this indicator. Could you clarify the expected logic?

  • 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: 2026_7860
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

PILLAR 3 - form EU CMS2 mapping for row EU 7d: Categorised as subordinated debt exposures in SA

According to official mapping for row EU 7d: Categorised as subordinated debt exposures in SA, column "d" and "EU d" include form c07-qx2062 that refers to CRE IPRE OTHER. Is intention to see CRE IPRE OTHER , or maping should be changed and include subordinated debt exposures?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/14 - Guidelines on materiality, proprietary, confidentiality and disclosure frequency under Pillar 3
  • ID: 2026_7838
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 12/05/2026

PILLAR 3 - form EU CMS2 mapping for columns d and EU d

According to mapping, column “d” and “EU d” refers to c07 and c10. Some of cells in column “d” and “EU d” refers only to c10. Please, could you explain the reason to exclude c07 from some cells in column “d” and “EU d”?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/14 - Guidelines on materiality, proprietary, confidentiality and disclosure frequency under Pillar 3
  • ID: 2026_7837
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 12/05/2026

Proportional application of K-ASA under Article 19 IFR in non-discretionary custody models linked to the operation of an MTF

Under Article 19 of Regulation (EU) 2019/2033, is there any scope for a more proportionate or risk-sensitive application of K-ASA where an investment firm: operates an MTF as its core activity; safeguards assets strictly on behalf of clients as direct participant in a CSD; does not exercise discretion over those assets; does not assume balance-sheet risk in relation to them; is prohibited from trading on own account or lending client securities; does not exercise voting rights, represent clients at meetings, or administer decisions regarding the underlying instruments; and has demonstrably reduced operational risk through technological investment and streamlined post-trade processes? More specifically: can competent authorities take into account the specific characteristics of such a business model when assessing the prudential effect of K-ASA, or is the calculation strictly volume-based in all cases regardless of the underlying risk profile; and is there any scope to differentiate K-ASA treatment depending on the type of instruments safeguarded, in particular between equity and debt instruments, or depending on whether the custody client is itself a regulated financial institution such as an investment firm or a bank?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7836
  • Topic: K-factor requirements
  • Date of submission:
  • Published as Rejected Q&A: 11/05/2026

Scope of the exemption under Article 7(7) with respect to Level 1 assets referred to in Article 10(1)(c)

Do the requirements laid down in Articles 7(5) and 7(6) of Delegated Regulation (EU) 2015/61 apply to assets referred to in Article 10(1)(c)?

  • 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_7835
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 29/05/2026

Own funds requirement for entities authorized as Crypto Asset Service Provider (CASP), Electronic Money Institution (EMI) and Investment Firm (IF)

How should own funds requirements be determined for a legal entity authorised as a crypto-asset service provider (CASP) under Regulation (EU) 2023/1114 (MiCAR), as an electronic money institution (EMI) under Directive 2009/110/EC, and as an investment firm under Regulation (EU) 2019/2033 (IFR) and Directive (EU) 2019/2034 (IFD), in particular where certain crypto asset services – such as the transfer of crypto assets on behalf of clients – require a specific CASP authorization rather than a notification regime, and given the absence of explicit provisions governing the interaction between the two prudential frameworks?

  • Legal act: Regulation (EU) No 2023/1114 (MiCAR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7834
  • Topic: Own Funds (MiCAR)
  • Date of submission:
  • Published as Rejected Q&A: 29/05/2026

Shadow Banking Definition - Alternative Investment Funds

Where an entity qualifies as an alternative investment fund (“AIF”) for the purposes of Directive 2011/61/EU, but its constitutive documents do not explicitly prohibit loan origination or the purchase of third‑party lending exposures, should that entity be regarded as meeting the criterion in Article 1(c)(iii) of the relevant Delegated Regulation 2023/2779 (Identification of Shadow Banking) solely on the basis of what it is permitted to do, notwithstanding that it does not in practice carry out banking activities, as referred to in Article 394(2) CRR? In particular, should the assessment of whether an AIF falls within the definition of a shadow banking entity be determined by: the theoretical scope of permitted activities under its rules or instruments of incorporation, or the actual activities carried out by the AIF in the ordinary course of its business?

  • 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: 2026_7833
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 29/05/2026

incoherent formulae

The formula of control v90322_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
  • ID: 2026_7821
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

When trying to submit reports to our portal Finanssivalvonta it gives us this error: An error occurred while converting CSV to XML. Error while reading CSV instance: error:unresolvableBaseMetadataFile ; : The resource "http://www.eba.europa.eu/eu/fr/xbrl/crr/fws/corep/4.2/mod/corep_of.json" is missing

When trying to submit reports to our portal Finanssivalvonta it gives us this error:     An error occurred while converting CSV to XML. Error while reading CSV instance: error:unresolvableBaseMetadataFile ; : The resource "http://www.eba.europa.eu/eu/fr/xbrl/crr/fws/corep/4.2/mod/corep_of.json" is missing. What does this mean? we cant seem to figure that out

  • Legal act: Other
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7820
  • Topic: Not applicable
  • Date of submission:
  • Published as Rejected Q&A: 29/05/2026

Pillar 3 Transparency - Risk weight missing in Template CCR3

Values with risk weight 30% are not allocated (according to the EBA Mapping Tool) to template CCR3, although these values appear in Row 185 of template COROFC C07.00. Is it intended to exclude values with 30% risk weight from template CCR3 (if yes, please provide the reasons for that) or is this a bug in die EBA mapping tool?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7819
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 11/05/2026

Definition of "official export credit agency" for the calculation of deduction for non-performing exposures

Article 47c(4a) of the CRR exempts the part of a non‑performing exposure guaranteed or insured by an “official export credit agency” (ECA) from the deduction requirements laid down in Article 47c. However, the CRR does not define the term “official export credit agency”. In this context, what are the criteria for qualifying as an “official export credit agency” and how can it be determined whether an export credit agency and the guarantee or insurance provided meets the criteria for applying the derogation as provided in CRR Article 47c(4a)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7818
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 12/05/2026

Z 09.02 (FMI2) FMI services reporting criteria

Could the EBA confirm the correct reporting criteria for columns 0040 (Critical Function ID) and 0060 (Core Business Line ID) in template Z 09.02 when an FMI is classified as either essential or critical, but not both, and the procedure to follow when an FMI maps to multiple functions or business lines?

  • 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_7814
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

Concerns on reporting on all relationships between investor and investee in Z01.02 of RESOL1 in alignment with the indication of key value as marked in the DPM 4.2 module

How to report correctly on the relationship of the investor (Z01.02, column 0020 “Code”) and the investee (Z01.02, column 0050 “Code”) when the investor invests in multiple investees? Could you please adjust the technical requirements stated in the Annotated Table Layout in the DPM 4.2 module (20260106 Annotated Table Layout RES 4.2 RESOL1RES 4.2.xls) and apply the setting of ‘Key value’ to both column 0020 as well as to column 0050?

  • 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_7813
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

Unique values in Z.01.02 in column 0020

How are institutions expected to report repeated values in column 0020 of template Z 01.02?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on the provision of information for the purpose of resolution plans
  • ID: 2026_7808
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

Application of Article 199(6)(d) for low default portfolios

In cases where institutions do not have a sufficient internal track record of default and liquidation events due to the low-default nature of certain portfolios, is there an alternative approach, such as the use of relevant external data, market evidence, or a combination of internal and external information, that could be considered acceptable to demonstrate compliance with Article 199(6)(d) for eligible physical collateral?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7806
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/05/2026

Z03.01 - Own funds requirements on individual level: r0300 / r0500 if a waiver exists

According to EBA validation rule v6433_m a minimum Total SREP Capital Requirement (TSCR) ratio (r0300) of 0.08 should be reported. However, the reporting subject has been granted a waiver from the minimum capital requirements under Article 92 CRR and is not required to comply with the 8% Total Capital ratios on a standalone basis, as these requirements are fulfilled and monitored at the consolidated group level. This also affects the "Overall capital requirement (OCR) ratio" (r0500) due to validation rule v6436_m. If the validation rule v6433_m will not be deactivated, which value needs to be reported in such cases?

  • 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_7804
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 29/05/2026

Z01.02 - Ownership structure: Investor code and type of code for multiple investments

According to the Annotated Table Layout of DPM 4.2, c0020 - Code (Investor Code), is specified as a unique ID in the template. According to the instructions for filling out the template, the specification must maintain referential integrity with Z01.01, provided that the investor is a group company.Since there can exist multiple investments per investor, it is not possible to comply with these requirements completely. How shall c0020 and c0030 (Type of code) be reported in such cases ? 

  • 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_7803
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

Z09.02 Requirement to Report CEF and Its Country When an FMI Only Supports a CBL

According to the EBA instructions, columns c0020, c0030, and c0040 are exclusively intended for essential FMIs (CEFs). However, in the template taxonomy, even when selecting “No” in column c0020 to indicate that the FMI is not a CEF, the system still requires completion of columns c0030 and c0040. We do not fully understand this requirement: if we have indicated that the FMI is not a CEF, we should not be expected to provide any CEF in column c0040, nor the CEF country in column c0030. Could you please advise on how we should proceed? As it stands, we would either need to enter an arbitrary CEF for FMIs that support a CBL but not a CEF, or the system should allow leaving columns c0030 and c0040 blank when c0020 = “No”.

  • 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_7799
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 29/05/2026