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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

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
  • ID: 2024_7285
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as final Q&A: 28/03/2025

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
  • ID: 2024_7284
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as final Q&A: 28/03/2025

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
  • ID: 2024_7283
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as final Q&A: 28/03/2025

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
  • ID: 2024_7281
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as final Q&A: 28/03/2025

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
  • ID: 2024_7280
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as final Q&A: 28/03/2025

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
  • ID: 2024_7279
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as final Q&A: 28/03/2025

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
  • ID: 2024_7278
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as final Q&A: 28/03/2025

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
  • ID: 2024_7277
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as final Q&A: 28/03/2025

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
  • ID: 2024_7276
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 11/04/2025

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)
  • ID: 2024_7274
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 28/04/2025

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
  • ID: 2024_7273
  • Topic: Other DORA topics
  • Date of submission:
  • Published as Rejected Q&A: 05/05/2025

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
  • ID: 2024_7272
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 28/04/2025

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
  • ID: 2024_7271
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 28/04/2025

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)
  • ID: 2024_7270
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 09/01/2025

Clarification of reporting of lending or financing where the use of proceeds is unknown in row 440 from Template 7 (ESG Disclosure)

Should all the instruments or lending against Sovereigns, where the use of proceeds is unknown, be excluded from the numerator of Template 7 ESG Disclosure - row 460 - Sovereigns and moved to row 440 - Other assets (e.g. Goodwill, commodities etc.)?

  • 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: 2024_7269
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 23/05/2025

Trade exposures to Qualifying Central Counterparties and collateral substitution

In case the original exposure is fully exempt from the application of the large exposure limit based on Art. 400 (1) (j) CRR as a trade exposure to a QCCP, no calculation of an exposure “after taking into account the effect of the credit risk mitigation in accordance with Articles 399 to 403” for purposes of the large exposure limit pursuant to Art. 395 (1) CRR takes place. Is accordingly a substitution of an exposure amount to the issuer of a security not required when the trade exposure to the QCCP is collateralised with the security, as the original exposure is fully exempt from the large exposure limit?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7268
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 21/01/2025

Standardised Approach Original Exposure pre conversion factors

Should all assets deducted from own funds be reported under Original Exposure pre conversion factors (C07.00 - column 0010) and hence considered as Value adjustments and provisions associated with the original original exposure (C07.00 - column 0030)

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2024_7267
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 13/02/2025

Contradiction between the Validation Rule EGDQ_0766a and Methodology

We kindly ask for a clarification in regard to Template C34.03: EBA Validation rule EGDQ_0766a requires that the Total number of transactions in template C34.02 must be higher or equal the Total number of transactions in Template C34.03. In Template C34.03 the total is calculated by the Software (Abacus) based on the Number of deals in separate Risk categories: "Interest Rate Risk", "Foreign Exchange Risk", "Credit Risk",   "Equity Risk"  and "Commodities". 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2024_7266
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2025

Proxy matrices

Are credit institutions (ASPSPs) allowed to facilitate proxy matrices implemented by their (corporate) clients that allocate proxy to only certain users to invoke the services of third party payment service providers (TPPs)?  

  • 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
  • ID: 2024_7265
  • Topic: Other topics
  • Date of submission: