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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

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

Template specific instructions – field B_01.02.0050 (Hierarchy of the financial entity within the group)

What does ‘where applicable’ mean in the title of data field B_02.01.0050?  What should be reported in this field in case the entity that is being reported in this template is not a financial entity (i.e., option 22, 23, or 24 was selected in field B_01.02.0040 for the entity type)?

  • 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

Intragroup transactions in calculation of net positions and own funds requirements for FX risk

i)When calculating the entity level positions and own funds requirements under Article 325b(4), are intragroup transactions allowed to be included ? ii)Same question for Article 352(2) determination of consolidated structural position

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

Reporting the fair value adjustments from macro fair value hedges in NSFR templates (C 80.00 and C 81.00)

When an institution did not opt under IFRS to present separately the fair value adjustments arising from macro fair value hedges, should the institution be required to include these adjustments separately solely for NSFR reporting, as other assets/liabilities, and not as part of the hedged item?

  • 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)

Financial entities subject to supervisory mechanisms as ICT third-party service providers.

Should financial entities providing ICT services to other financial entities (even if these ICT services are ancillary to regulated financial services)  be considered as ICT third-party service providers under the Regulation (EU) 2022/2554 and, consequently, should their contractual arrangements for the use of relevant ICT services include the key contractual provisions set out in Article 30 of the DORA Regulation; or otherwise, does the fact that these entities are already authorised/licenced/registered mean that they should not be considered as ICT providers and, therefore, that their contractual arrangements do not need to contain the requirements set out in Article 30?

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

Denominator for GAR Green Asset Ratio (%) Calculation

Which denominator should be used in the GAR KPI templates: the corresponding Total gross carrying amount (column a) of the respective rows in template 7 "Mitigating actions: Assets for the calculation of GAR", (for example if the GAR is computed for line 0020 'Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation' in case of numerator is used the loans and advances, for example Of which environmentally sustainable Taxonomy-aligned, and in the denominator should be the similarly filtered Total gross carrying amount from the same row of template 7; The denominator should be unique, disregarding the formula level: "Total GAR assets" line 320  or  The denominator should be unique, disregarding the formula level: "Total assets in the denominator (GAR)" line 0450 ?

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

OFR for operational risk on the date 31 December 2024

What method should we use to calculate the OFR on 31 December 2024 (e.g. to present in COREP 16.00) - new standardised approach according to CRR3 or one of existing approaches (BIA, TSA, AMA)?

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

Definition of residential/commercial immovable property in FINREP reporting under CRR3

What should be considered as ‘residential / commercial immovable property for financial reporting purposes (FINREP)? Do the definitions change under CRR3?

  • 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)