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List of Q&A's

The control formula v11888_m lacks sufficient evidential value.

Only the Total sheet  ([eba_qAE:qx2023]) must be empty for column 0050 (PD).  Should control over another sheet (other than [eba_qAE:qx2023]) really exist ? Should it not be deleted ?

  • 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_7951
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

The control formula v10666_m lacks sufficient evidential value.

The control rule in place is incompatible with the EBA Filing Rules - section 2.18 on decimal precision requirements. Could these rules be amended?

  • 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_7950
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

The control formula v10664_m lacks sufficient evidential value.

The control rule in place is incompatible with the EBA Filing Rules - section 2.18 on decimal precision requirements. Could these rules be amended?

  • 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_7949
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026

Validation Rule v22950_m – warning generated for exposure class [eba_qEC:qx2038] in C 07.00a

Validation rule v22950_m requires that cells in C 07.00a, row 0062 are blank for exposure class [eba_qEC:qx2038] – “Exposures secured by mortgages on immovable property and ADC”. However, the instructions for row 0062 state: “of which: IPRE exposures where the derogation set out in Article 125(2) of Regulation (EU) No 575/2013, second subparagraph is applied. Only reported in sub-exposure class ‘Secured by mortgages on residential immovable property – IPRE’.” According to the DPM hierarchy, qx2038 is the parent exposure class of – ‘Secured by mortgages on residential immovable property – IPRE’. As amounts reported are reflected in the corresponding parent exposure class, the inclusion of qx2038 in validation rule v22950_m generates a warning despite the reporting being consistent with the instructions.  Rule Reference: isnull ({tC_07.00.a, r0062, (c0010, c0030, c0040, c0150, c0160, c0165, c0170, c0175, c0180, c0190, c0195, c0200, c0215, c0220), default: null, interval: false} [ where qEBB in {[eba_qEC:qx16], [eba_qEC:qx23], [eba_qEC:qx22], [eba_qEC:qx21], [eba_qEC:qx20], [eba_qEC:qx19], [eba_qEC:qx2043], [eba_qEC:qx2036], [eba_qEC:qx2060], [eba_qEC:qx2037], [eba_qEC:qx2061], [eba_qEC:qx2063], [eba_qEC:qx2049], [eba_qEC:qx12], [eba_qEC:qx2050], [eba_qEC:qx13], [eba_qEC:qx18], [eba_qEC:qx14], [eba_qEC:qx1], [eba_qEC:qx25], [eba_qEC:qx26], [eba_qEC:qx2038], [eba_qEC:qx2039], [eba_qEC:qx2040], [eba_qEC:qx2041]}]) 

  • 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_7946
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

Validation rule EBA_v22949

Validation rule v22949 should be deactivated as it is not in line with reporting instructions.

  • 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_7942
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026

CVA exemptions: marginal impact of reintegration

Annex II of the ITS requires to show the marginal impact of reintegration of CVA exemptions, separately for each exemption. it defines the marginal impact as "the difference, expressed in absolute amount, between the relevant metric for the scope of transactions referred to in row 0010 after reintegrating the exemption, and the relevant metric for the scope of transactions referred to in row 0010".  This statement may in our opinion be interpreted in two different ways: For each of the 7 exemptions and for the whole portfolio including the exemptions, institutions are required to calculate the cva risk charge for the non-exempted portfolio + the relevant exemption separately and report the difference to the cva risk charge calculated for the non-exempted portfolio. This requires 8 separate calculations and the marginal impact of individual exemptions will be accurate. However, the marginal impact for the individual exemptions will not add up to the marginal impact for the whole portfolio. Institutions are required to calculate the difference of the cva risk charge calculated for the whole portfolio to the cva risk charge calculated for the non-exempted portfolio. This difference will be split up for the 7 exemptions using the contributions on counterparty level already calculated for the whole portfolio. This requires 1 separate calculation and the marginal impact for individual exemptions will add up to the marginal impact for the whole portfolio. However, the marginal impact of each individual exemption will be only approximate (i.e. scaled by counterparty contributions). Question: are institution allowed to use method (2)?

  • 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_7941
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Classification of spread components of floating-rate instruments for contractual repricing reports

How should institutions classify the fixed spread component of a floating-rate instrument when reporting IRRBB repricing cash flows? Article 7 of Commission Implementing Regulation (EU) 2024/857 requires institutions to allocate the spread components of floating-rate instruments "up to the final contractual maturity, irrespective of any repricing of the non-amortised principal". However, Annex V, Section 3, states that the distinction between fixed-rate and floating-rate instruments is to be applied at instrument level. Under this definition, an instrument whose interest payments are contractually linked to an external benchmark is classified as a floating-rate instrument. In practice, two alternative interpretations have emerged: Cash-flow level interpretation: the fixed spread component of a floating-rate instrument is treated as a fixed-rate cash flow extending until contractual maturity and therefore reported within the fixed-rate section of the repricing templates. Instrument level interpretation: the spread component remains associated with the floating-rate instrument and is therefore reported within the floating-rate section, even though Article 7(c) requires the spread cash flows to be allocated up to final maturity. Should institutions report the spread components of floating-rate instruments in the fixed-rate section because they are allocated until final contractual maturity under Article 7(c), or should they remain in the floating-rate section because the fixed/floating classification applies at instrument level according to Annex V?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
  • ID: 2026_7940
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Treatment of bank guarantees posted by clearing members as initial margin for the purpose of NICA in the CCP hypothetical capital (KCCP) calculation under Article 50a of EMIR

When a CCP calculates the hypothetical capital requirement (KCCP) pursuant to Articles 50a-50b of Regulation (EU) No 648/2012 (EMIR), as amended by Regulation (EU) 2019/876, applying the SA-CCR methodology set out in Part Three, Title II, Chapter 6, Section 3 of CRR, can bank guarantees provided by that clearing member be recognised as part of the collateral in the NICA term, provided that they are contractually pledged to the CCP and can be drawn upon in the event of the clearing member’s default? If the answer to Question 1 is negative and Article 276(1)(a) and (b) of CRR should be applied in full such that the only collateral eligible for inclusion in the NICA is that which qualifies as eligible financial collateral under Article 197 CRR (and Article 299 CRR for netting sets belonging entirely to the trading book), should a CCP assign a value of zero to bank guarantees posted by clearing members as initial margin when computing the Replacement Cost and the PFE multiplier? Or is there an alternative treatment available under the SA-CCR framework that would allow a CCP to partially or fully reflect the risk-mitigating effect of such guarantees in the EAD calculation?

  • Legal act: Regulation (EU) No 648/2012 (EMIR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7937
  • Topic: Market infrastructures
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Methodology for calculating the scenarios referred to in Article 25(2), (3), and (4), as well as point 5(a), (b), and (c) of the Annex to the Regulation.

Our Bank as another non-listed institution, as part of the CRR Regulation, is required to apply the "standardized approach" for interest rate risk, as defined in Regulation 2024/857. Banks subject to the simplified standardized methodology apply, by way of derogation from Article 8(9), the pass-through rate specified in point 5(a), 5(b), and 5(c) of the Annex. Our Bank, as another non-listed institution, should independently calculate the pass-through rate, taking into account the Bank's historical data for the base scenario and scenarios predicting a decrease and an increase in short-term interest rates. Currently, the Bank applies the pass-through rate from points 5a, 5b, and 5c of the Annex to the Regulation. Since the UKNF has issued a recommendation that the Bank independently determine the pass-through rate, please provide the methodology for calculating the scenarios referred to in Article 25(2), (3), and (4), as well as point 5(a), (b), and (c) of the Annex to the Regulation.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/857 - RTS on the IRRBB standardised approach
  • ID: 2026_7933
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 11/08/2026

Completion of the Z08.02 Template

In Z_08.02, are we expected to map operational assets to external services or only to intra-entity services?  If we are expected to map operational assets to external services, for external services which relate to support we receive on IT systems, should columns 0030, 0080, 0040 and 0050 be populated with data related to the respective IT system or should they be left blank? Additionally, if we report a service related to physical transportation of cash, should columns 0030, 0080, 0040 and 0050 be left blank considering that we don't need any asset to receive the service from the external provider?    

  • 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_7927
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 18/09/2026

Template Z08.02: Reporting of applications owned and operated by affiliated service providers

Where a reporting entity receives services from an affiliated entity and relies on applications that are owned, managed and operated by that affiliated service provider, should those applications be reported in template Z08.02 by the receiving entity?Alternatively, should template Z08.02 be limited to operational assets that are owned, managed or directly controlled by the reporting entity, with dependencies on affiliate-owned applications being reflected through the relevant service provider and outsourcing/inter-affiliate reporting templates?

  • 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_7926
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 18/09/2026

Instructions to follow regarding new EBA Resolution Reporting - Template Z 07

Could the EBA please confirm whether column “0030” (and, for template Z 07.01.4, also columns “0040” and “0050”) should be populated with amounts referring to the entire customer base, irrespective of residence, or with amounts referring only to customers resident in the home country?

  • 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_7924
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026

Risk weights assignment to IPRE exposures secured by many properties

Articles 125 and 126 paragraph 2 Regulation (EU) No 575/2013 (CRR) specify the rules for risk weights assignment to IPRE exposures, respectively secured by residential and commercial properties. However, these regulations don’t clarify how risk weights should be assigned to IPRE exposure when it’s secured by both residential and commercial property – especially when one property is IPRE (income producing property) and the second one is non-IPRE (the residential property, let’s assume that this is the flat of a counterparty). 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7923
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 06/07/2026

Clarification of ETV calculation for mortgages securing more than one exposure

Article 124 paragraph 6 Regulation (EU) No 575/2013 (CRR) specifies the calculation of ETV for IPRE exposures. In order to calculate ETV, the gross value of an exposure should be divided by the value of property. Additionally, this article clarifies that: “For the purposes of the first subparagraph, point (a), where an institution has more than one exposure secured by the same immovable property and those exposures are secured by liens on that immovable property that are sequential in ranking order without any lien held by a third party ranking in-between, the exposures shall be treated as a single combined exposure and the gross exposure amounts for the individual exposures shall be summed up to calculate the gross exposure amount for the single combined exposure.” Our question refers to calculation ETV for joint mortgages – so the mortgage which secures more than one exposures and additionally these exposures may have other mortgages assigned. Based on the above, it’s clear that numerator should include the gross value of all exposures secured by this joint mortgage. Nevertheless, it’s unclear which value should be used in the denominator of ETV in the real life example described below.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7922
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 06/07/2026

Definition of "main business" under CRR

How are banks to interpret the concept of "main business" in Article 411(1) of Regulation (EU) No 575/2013 (CRR), read in conjunction with Annex I of Directive 2013/36/EU and Article 3(9) of Commission Delegated Regulation (EU) 2015/61? In particular: can an entity be considered to perform Annex I CRD activities as its "main business" within the meaning of Article 411(1) CRR if: there is an absence of any third-party commercial activity i.e. entity does not offer financial services to any external party for commercial consideration nature of the entity’s operations is ancillary to the group and it exists solely as an instrument of the group's non-financial operations with no independent commercial purpose

  • 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_7921
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 06/07/2026

Reporting obligations under Article 3 of the CIR

Whether, and to what extent, will the reporting obligations concerning Relevant Legal Entities (RLEs) under Article 3 of the CIR also apply where a recently acquired RLE is expected, with a high degree of certainty, to cease to exist as a legal entity prior to the adoption of the resolution plan as a result of a legal merger. Additionally, how should this acquired entity be treated for the purposes of resolution planning and related reporting obligations during the interim period between its acquisition and its absorption through merger? We wonder if resolution authorities (RAs) may waive the reporting obligations for this acquired entity for the first reporting cycle after acquisition. Against this background, does the framework require or allow a reclassification of the acquired entity (which used to be a Liquidation entity before acquisition with no reporting obligations) as an RLE immediately upon acquisition, implying inclusion in the group’s resolution plan and submission of the applicable reporting templates? Alternatively, may the acquired entity continue to be treated as a liquidation entity until the legal merger is completed, with its status and standalone reporting obligations remaining unchanged during the interim period? Clarification is sought on whether, in the context of M&A transactions, resolution authorities are expected to adjust the entity’s classification upon acquisition, or whether they may maintain the pre-acquisition status until legal integration is finalised.

  • 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_7918
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Definition of “Substitutability” of CCPs and the connected reporting of “Alternative Providers” for the purpose of the template Z 09.04 (RESOL II).

Should the concept of substitutability of CCPs, and consequently the identification of alternative providers to be reported in template Z 09.04, be interpreted restrictively, i.e. limited to CCPs or intermediaries that are capable of providing an equivalent clearing service for the same trading venue and/or market(s)? Or should a broader interpretation of substitutability be applied, focusing on the economic function, business and regulatory objectives as well as the post-trade nature of the clearing service, under which a CCP might be substitutable not only by a concurrent CCP active on the same market, but also by: the substitution of the entire trade value chain (e.g. trading venue – CCP – CSD or trading venue – CSD); or the use of an intermediary/broker capable of rerouting either the trading and clearing activity or the transactions executed on behalf of the reporting institution through alternative FMIs, provided that such arrangements achieve a comparable economic and functional outcome for the reporting institution.

  • 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_7912
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 09/10/2026

Treatment of the Right Way Risk in Call Warrant

Is a call warrant issued by the counterparty  that is also the issuer of the underlying shares exempt from counterparty credit risk requirements?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7911
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Validation Rule RRCOROF_V903610_H_C0030

Could you please clarify the validation rules newly introduced or reactivated in template C34.03 within COROFI and COROFC as of 31 March 2026? These rules require that the totals for Number of Transactions (RRCOROF_V903610_H_C0030_S0001), Nominal Amount (RRCOROF_V903610_H_C0040_S0001), Positive Market Value (RRCOROF_V903610_H_C0050_S0001 ) and Negative Market Value (RRCOROF_V903610_H_C0060_S0001)  and Add-on (RRCOROF_V903610_H_C0070_S0001) equal the sum of the respective risk categories (Interest Rate Risk, Foreign Exchange Risk, Credit Risk, Equity Risk, Commodities Risk, Other).     

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7910
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 31/08/2026

Changes between DPM 4.0 and DPM 4.2: An error has occurred while performing schema validation for the node '{http://www.eba.europa.eu/xbrl/crr/dict/met/4.2}ei86': "Other Countries" does not parse as a QName value. C_14.00 TC_14.00-L005-C0190 = Other Countries

Given that the "other countries" code was removed from  the DPM 4.2, how should these exposures be reported in COREP? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7908
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/10/2026