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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.

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List of Q&A's

Clarification on the application of Article 215.2(b) of the CRR

Can guarantees issued by a central government for residential mortgages, that covers losses resulting from the non-payment of interest and other types of payments which the borrower is obliged to make, be used for unfunded credit protection if the final guarantee value is determined based on the residual value between an executive sale of underlying residential mortgage collateral and a max guaranteed amount?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7666
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 27/02/2026

reverse solicitation

The reverse solicitation is where a client or counterparty approaches an undertaking established in a third country at its own exclusive initiative for the provision of banking services, including their continuation, or banking services closely related to those originally solicited.  Is the invitation letter from the agent bank who arranges for the syndicated loans or Schuldscheindarlehen ("SSD") a sufficient supporting document to evidence that a client approaches us at its own exclusive initiative? Or an independent declaration directly made from the borrower (the client) is required?  

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7665
  • Topic: Passporting and supervision of branches
  • Date of submission:
  • Published as Rejected Q&A: 22/01/2026

Validation rules taxonomy V4.0 C_47.00, C_43.00.a, C_43.00.b, C_43.00.c - v4456_m

Validation rule v4456_m is a consistency check between the total leverage exposure value before "Asset amount deducted - Tier 1 capital" in C 47.00 (LRCalc) and exposure values reported in C 43.00.a/b/c: sum ({tC_47.00, r0010-0269, c0010}) + {tC_47.00, r0900, c0010} + {tC_47.00, r0910, c0010} = sum ({tC_43.00.a, (r0010, r0040, r0050, r0060, r0065, r0070), c0010}) + sum ({tC_43.00.b, (r0080, r0090, r0140, r0180, r0190, r0210, r0230, r0280, r0290), c0010}) + sum ({tC_43.00.c, (r0080, r0090, r0140, r0180, r0190, r0210, r0230, r0280, r0290), c0020}) Validation rule v4456_m and the instructions provided by the EBA for forms LR4 and LRCalc are inconsistent with respect to “General credit risk adjustments to off balance sheet items” (LRCalc row 0181) and “Excluded guaranteed parts of exposures arising from export credits” (if related to off balance sheet exposures, part of LRCalc row 0252). Please provide instructions in which row(s) the amounts in LRCalc in rows 0181 and 0252 (if related to off balance sheet exposures) should be reflected in form LR4.

  • 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: 2025_7664
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 03/07/2026

Scope of reporting in Z01.01

Please clarify which scope of consolidation should be applied within the reporting template. Please clarify as well how the reconciliation to the respective measures should be performed depending on the first clarification. 

  • 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: 2025_7663
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Counterparty treatment of Debt Management Offices (DMOs)

How should Debt Management Offices (DMO) be treated in liquidity reporting for counterparty classification purposes?

  • 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: 2025_7662
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 31/03/2026

Applying the provisions of Article 390 (7) CRR and Delegated Regulation 1187/2014 for determining the overall exposure to a client or a group of connected clients in respect of transactions with underlying assets for received collaterals (indirect exposures) after applying substitution approach according to Article 403 CRR 

Does a credit institution have to apply the provisions of Article 390 (7) CRR in combination with Delegated Regulation 1187/2014 to a securitization or investment fund exposure, when the credit institution received the securitization or investment fund exposure as a collateral in an SFT?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1187/2014 - RTS for determining the overall exposure to a client or a group of connected clients in respect of transactions with underlying assets
  • ID: 2025_7661
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 13/01/2026

FINREP Identical Cells 5458783, 5458788, 5459395, 5460187

Could the EBA confirm whether these identical cell checks are correct? If not, should they be updated to align with the previous logic (v8610_i, v8611_i, v10006_i, v10007_i) to ensure consistency between templates and definitions?Please clarify the intended scope of collateral reporting in these templates and whether the current rules will be revised.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7660
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 23/12/2025

FINREP Validation rules v23845_h, v23846_h, v23847_h

Could the EBA clarify the rationale for excluding rows 0015, 0185, and 0365 from the new validation rules for template F 12.01.a?This change creates inconsistencies with cross-template validation rules such as: v6030_m: {tF_12.01.a, r0010, c0100} - {tF_12.01.a, r0015, c0100} = {tF_04.03.1, r0180, c0050} + {tF_04.04.1, r0140, c0050} v6033_m: {tF_12.01.a, r0180, c0100} - {tF_12.01.a, r0185, c0100} = {tF_04.03.1, r0180, c0060} + {tF_04.04.1, r0140, c0060} v6036_m: {tF_12.01.a, r0360, c0100} - {tF_12.01.a, r0365, c0100} = {tF_04.03.1, r0180, c0070} + {tF_04.04.1, r0140, c0070} These rules assume that rows 0010, 0180, and 0360 include “Cash balances at central banks and other demand deposits.” Additionally, the items “of which: collectively measured allowances” and “of which: individually measured allowances” will no longer consider these balances because the related rules (v5054_m, v5055_m, v5056_m) reference rows 0010, 0180, and 0360 only. Could the EBA confirm whether this exclusion is intentional and, if so, provide guidance on how to reconcile these templates and validation rules?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7659
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 23/12/2025

Validation rule v89325_m is not correct

Validation rule v89325_m should be deleted as it is not in line with reporting guidance and inconsistent with corresponding P3 data hub validation rules.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2025_7658
  • Topic: Supervisory reporting
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Validation rule v89319_m is not correct

Validation rule v89319_m is incorrect for c0110. Percentages cannot be summed up.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2025_7657
  • Topic: Supervisory reporting
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

J 09.00.a : Column 020 of lines 160, 220 and 300

Please note that column 020 of lines 160, 220 and 300 of report J 09.00.a should have the same data points as those of report J 08.00.a, as is the case for column 010.  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7656
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Controls v4968_m, v5024_m, v5372_m, v5373_m and v5376_m

Please note that controls v4968_m, v5024_m, v5372_m, v5373_m and v5376_m should have the condition "eba_qAS:qx2004" instead of "eba_AS:x2" to comply with column 010 of row 010 of report F_00.01

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7655
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 23/12/2025

C_07.00 : columns 010 to 040 of line 210

I would like to point out that columns 010 to 040 of line 210 of report C_07.00 should have been ungreased in the EBA 4.2 taxonomy to be in accordance with the EBA's answer to question 2025_7348.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7654
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 23/12/2025

incoherent formulae

Should the v903188_s control formula apply to columns 0010 and 0020?

  • 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: 2025_7653
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

incoherent formulae

Should the v903188_s control apply for establishments that do not supply the C16.04 status?

  • 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: 2025_7652
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

incoherent formulae

Is the v90304_m control formula consistent with the other controls on C16.02 ?

  • 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: 2025_7651
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

Foreign Exchange Vega Risk Factors Definition

Shall the foreign exchange vega risk factors to be applied by institutions to instruments in the CVA portfolio sensitive to foreign exchange volatility be the implied volatilities of foreign exchange rates between the contractual currency pairs (i.e., no triangulation with respect to the institution’s reporting currency is required)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7650
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2026

Calculation of the unmargined exposure value for a netting set with multiple margin agreement or including both transaction subject to a margin agreement and transaction not subject to a margin agreement

How to calculate the capped exposure value, i.e., the exposure value of the netting set in the event that it is not subject to any type of margin agreement, when there are multiple margin agreements applicable to this netting set or when this netting set includes both transactions subject to a margin agreement and transactions not subject to a margin agreement? For the calculation of the unmargined value, should all deals be included in a single sub-netting set (the one containing contracts not subject to margining) and not divided as required by paragraph 4 of Article 274, or should the sub-netting sets remain separate and their value be calculated as if they were unmargined?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7649
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 26/01/2026

ESG P3 - Template 1 - NACE I classification

The formulas linked to the following rule IDs: v12723_m and v12724_m appears to be incorrect.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2025_7648
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Template C90.00 and C90.05

For the purpose of determining the "On- and off-balance sheet business subject to market risk" for template C90, is the netting between long and short positions in the same exact instrument allowed? 

  • 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)
  • ID: 2025_7647
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 26/01/2026