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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

Definition of financial institution under Article 4(1)(26)

Does the definition of financial institution under Article 4(1)(26) CRR include trust companies under Liechtenstein law?

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

Definition of ancillary services undertaking under Article 4(1)(18)

Does the definition of ancillary services undertaking under Article 4(1)(18) CRR include trust companies under Liechtenstein law?

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

Remittance date for quarterly iMREL/iTLAC Q1 2025

Will the remittance date for Q1 2025 iMREL/iTLAC reporting be aligned to the due date for COREP reporting for which the submission date is postponed to June 2025?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/763 – ITS with regard to the supervisory reporting and public disclosure of MREL

The scope of the regulation described in Article 6 mismatches what is presented as an option in the Annex I, Part 2 of the same regulation

Do financial entities must include non-financial entities within the same group in the Register of Information? If not, why is there an option to do so?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information

Validation Rule for Marginal Impact of Reintegration of CVA Exemptions

The guidance for the population of rows 0040-0110 specifies that firms should populate the marginal impact of reintegration of CVA exemptions "separately for each exemption". However there is a warning validation rule v23083_m which specifies that the sum of the individual exemptions should be equal to the total "{r0040} = {r0050} + {r0060} + {r0090} + {r0100} + {r0110}". We would like to query whether the validation rule is valid and therefore whether we should be calculating a single CVA exemption reintegration impact of excluded transactions and then attributing by type of exemption or genuinely calculating the marginal impact separately by type of exemption. 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Requirements for the purpose of treating exposures secured by mortgages on immovable property as duly secured from an RWA computation perspective under CRR Article 124(2) of the CRR.

Can a global insurance against damages on a portfolio of exposures secured by immovable properties subscribed directly by the lending institution be considered as compliant with the requirement of Article 208(5) of the CRR - that is to say considered, under the standardized approach, as meeting the operational requirements for the purpose of treating exposures secured by mortgages on immovable property (or in case an institution has opted for the application of article 108(5)(a) allowing to consider a guaranteed exposure as an exposure secured by a mortgage on immovable property) as duly secured from an RWA computation perspective under Article 124(2) of the CRR?

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

Clarifications on the perimeter of templates 2 and 5 Collateralized loans portfolio

The Bank would like to clarify whether the same perimeter should be applied in ESG Pillar 3 Templates 2 and 5 regarding loans collateralized by residential/commercial property in column 010 (Gross Carrying Amount). Specifically, Template 2 requires banks to disclose the energy efficiency of the collateral for loans secured by immovable property, including cases where the Energy Performance Certificate (EPC) is available or unavailable, with the percentage of estimated EPCs provided when the certificate is unavailable. Based on this guidance, it seems that Template 2 would include only assets eligible for Energy Performance Certification as per relative legislation, as EPCs cannot be defined for non-eligible assets. In contrast, Template 5 would appear to cover both EPC-eligible and non-eligible assets. It would be helpful to understand if this interpretation aligns with the intended approach and whether column 010 of Template 2 should specifically reflect the subset of loans collateralized by residential/commercial property that are eligible for EPC.

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

Applicability of DORA and TFR requirements to VASPs

Do the requirements of the Digital Operational Resilience Act (DORA) and the Transfer of Funds Regulation (TFR) apply to Virtual Asset Service Providers (VASPs) that are not classified as Crypto-Asset Service Providers (CASPs) under the Markets in Crypto-Assets Regulation (MiCAR) as of December 30, 2024 and are benefiting from the MiCAR transition period?

  • Legal act: Directive 2022/2556/EU (DORA Dir)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Reporting framework 4.0 Validation rules release (new format) (Uploaded on 19/12/2024)

In light of the validation rules release (new format) published on 19 December 2024 on your website, we have identified potential issues with the following validations: Validation v0329_m: This rule checks that the value in COREP template C_07.00.a, column 0220, equals the sum of columns 0215, 0216, and 0217. However, the ITS stipulates that column 0215 reflects values before currency mismatch, columns 0216 and 0217 represent adjustments for supporting factors, and only column 0220 should account for currency mismatch adjustments. The validation v0329_m appears to disregard the intended adjustment logic for currency mismatch, making the rule inconsistent with the ITS requirements. Validation v0407_m: This rule checks that the value in COREP template C_09.01.a, column 0090, equals the sum of columns 0080, 0081, and 0082. The ITS specifies that columns 0080–0090 in C_09.01.a should correspond directly to columns 0215–0220 in C_07.00.a. Given that column 0220 in C_07.00.a includes adjustments for currency mismatch, the requirement for column 0090 to equal the sum of columns 0080, 0081, and 0082 is contradictory to the ITS logic. Based on these observations, we believe that both validations, v0329_m and v0407_m, are incorrect. We kindly request your confirmation and guidance on this matter, including any planned revisions to these validations.  

  • 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 (repealed)

Applicability of Regulation (EU) 2022/2554 (DORA) to ICT services provided by financial entities.

Clarification is needed on whether financial institutions providing ICT services to other financial institutions – regardless of whether these services are ancillary to regulated financial activities – can be qualified as ICT third-party service providers under Regulation (EU) 2022/2554. If they are, must their contractual relationships comply with the mandatory provisions outlined in Article 30 of the mentioned Regulation or are these requirements inapplicable since such entities are already authorised/licenced/registered? 

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

C14.00 - v7364_m - Type of Assets (column 0160)

According to EBA Q&A 2023_6864 the validation rule v7364_m is not in line with the current regulatory provisions and shall be deleted. However, in the latest revised list of ITS validation rules as per September 2024 the rule is still active. Could you please amend the validation rules and deactivate the rule as per the above mentioned Q&A.

  • 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 (repealed)

Knowledge element of SCA.

Can an API key be considered as a Knowledge element of SCA?

  • 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

Template specific instructions – primary keys

How to report data fields in case of missing values?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information

Template specific instructions – field B_05.02.0060 (Identification code of the recipient of sub-contracted ICT services)

How to report data field B_05.02.0060 if the ICT third-party service provider is a direct provider (rank =1)?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information

Template specific instructions – field B_05.01.0020 (Type of code to identify the ICT third-party service provider)

How to report type of identification code in data field B_05.01.0020 when using codes other than LEI or EUID?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information

Template specific instructions – field B_02.02.0160 (Location of management of the data)

How to report data field B_02.02.0160 where the ICT service is not based or does not foresee data processing?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information

Template specific instructions – field B_02.02.0130 (Country of the governing law of the contractual arrangement)

How to report field B_02.02.0150 where the ICT service is not related to storage of data (B_02.02.0140 = 'No')?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information

Template specific instructions – field B_02.02.0130 (Country of the governing law of the contractual arrangement)

How to report field B_02.02.0130 where the ICT service is not supporting a critical or important function considering that according to the data model this data field is a primary key?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information

Template specific instructions - field B_01.02.0060 (LEI of the direct parent undertaking of the financial entity)

What should be reported in case the financial entity does not have a direct parent undertaking (for example, is the parent undertaking itself) or reports the register on an individual basis?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information