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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

Validation rules taxonomy V4.0 C10.00 v23054_m

According to the formulae v23054_h : {r0150} >= {r0151} in C10.00.This control indicates that the row r0150 “Secured by mortgages on immovable property and ADC exposures” must be superior to row r0151 “  Of which: Exposures secured by mortgages on residential property up to 55% of the property value” on all report rows.However, the formula of control v23086_m indicates that only row r151 must be reported on memo item column c0090 "EXPOSURES SECURED BY MORTGAGES ON RESIDENTIAL PROPERTY UP TO 55% OF THE PROPERTY VALUE" so the first control cannot be compliant as row r150 must be empty. This also applies to rows r150 and r151 on memo item columns c0100, c0110 and c0120 as formulae v23087_m and v23088_m indicate that, respectively, only rows r0152 and r0101 should be reported on, respectively, columns c0100 and c0110.Could you please therefore confirm that the control v23054_m needs to be modified and should apply to all columns except memo items columns?

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

COREP_OF, C_07.00, problem with disallowed risk weight 70%

Why are cells r0210-c0010, r0210-c0030, and r0210-c0040 (Risk Weight 70%) in table C_07.00 disallowed despite CRR3 Article 126 allowing a 70% risk weight for certain exposures (ETV ≤ 60%)?

  • 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

COREP_OF, C_07.00, problem with disallowed risk weight 70%

Why are cells r0210-c0010, r0210-c0030, and r0210-c0040 (Risk Weight 70%) in table C_07.00 disallowed despite CRR3 Article 126 allowing a 70% risk weight for certain exposures (ETV ≤ 60%)?

  • 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

Calculation of the SME supporting factor for off-balance-sheet exposures

Is the SME supporting factor applicable, and if so, how shall it be computed, in case there is no on-balance-sheet exposure to be included in E*, as defined in Article 501(1) of CRR?

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

Prudential treatment of goodwill and other intangible assets arising from the acquisition of an asset manager by an insurance undertaking fully owned by a bank

For the purposes of a deduction under Articles 36(1)(b) and 37 of the CRR, should a bank, which owns 100% of an insurance undertaking which acquires a controlling shareholding in an asset manager, deduct goodwill and other intangible assets (Article 4(1)(113) and (115) of the CRR) generated by the acquisition carried out by its insurance undertaking subsidiary?

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

breakdown of total exposures by risk weights

How should exposures subject to a risk weight of 70% according to Art. 126 (2) CRR3 be reported in the ITS on supervisory reporting v4.0? Should these exposures be included in the row r0280 “other risk weights” of the template C 07.00?

  • 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

DPM 4.0 taxonomy, several validation rules are not correct

During the analysis of DPM 4.0 taxonomy, we identified the following issues in the validation rules: EBA validation rule, v23083_m (C25.01) Current rule: with {tC_25.01.a, (c0010, c0020, c0050, c0060, c0070, c0090, c0100, c0110, c0140, c0150, c0160, c0170, c0180, c0200, c0210, c0220, c0230, c0240, c0250, c0270, c0280, c0290), default: 0, interval: true}: {r0040} = {r0050} + {r0060} + {r0090} + {r0100} + {r0110} Proposal: the rule should be deactivated Reason: CVA-risk amounts can be non-additive due to portfolio effects   EBA validation rule, v23345_s  (C25.01) Current rule: with {tC_25.01.a, default:null, interval:false}: {(r0010, r0020, r0030, r0040, r0050, r0060, r0070, r0080, r0090, r0100, r0110, r0130), (c0010, c0020, c0060, c0100, c0110, c0140, c0150, c0160, c0170, c0180, c0200, c0210, c0220, c0230, c0240, c0250, c0270, c0280, c0290)} >= 0 Our Proposal: the rule should be deactivated Reason: Marginal CVA-risk amounts can be negative due to portfolio effects   EBA validation rule, v23710_s  (C25.01) Current rule: with {tC_25.01.a, default: null, interval: false}: {(r0010, r0020, r0030, r0040, r0050, r0060, r0070, r0080, r0090, r0100, r0110, r0130, r0230, r0240), (c0070, c0090)} >= 0 Our Proposal: the rule should be deactivated Reason: Marginal CVA-risk amounts can be negative due to portfolio effects   Mapping Pillar 3 disclosures templates with supervisory reporting (Template EU CMS2. Column d) Column d (RWEAs calculated using full standardised approach) shows the relevant Output-Floor S-TREA without Floor transitional rules according to CRR Article  465 (3) – (13). It is calculated as a surcharge of the current Output Floor S-TREA. But the values from Template C10.00  for transitional rules regarding  EXPOSURES SECURED BY MORTGAGES ON RESIDENTIAL PROPERTY are missing and must be included analogous to template EU CMS1 (à there: {C10.00, r0010, c0090} + {C10.00, r0010, c0100}).    EBA Validation rule v1659_m (C07.00) Current rule: {c0200} = {c0150} - {c0160} - ( 0.90 * {c0165}) - ( 0.8 * {c0170}) - ( 0.6 * {c0175}) - ( 0.5 * {c0180} - {c0195}) Proposal: {c0200} = {c0150} - {c0160} - ( 0.90 * {c0165}) - ( 0.8 * {c0170}) - ( 0.6 * {c0175}) - ( 0.5 * {c0180}) - {c0195} Reason: the term  {c0195} should be excluded from the 0.5-weight-bracket, because UCCs have under the transitional arrangement a 0% CCF and must be subtracted completely.   EBA Validation rule v6052_m (C 09.02) Current rule: {r0150} = {r0010} + {r0011} + {r0012} + {r0013} +{r0020} + {r0030} + {r0060} + {r0132} +{r0140} Proposal: {r0150} = {r0010} + {r0012} + {r0013} +{r0020} + {r0030} + {r0060} + {r0132} +{r0140} Reason: the "of which" position should not be part of the sum. 

  • 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)

Presentation of fully matured loans and deposits in templates F05.01 and F08.01

Could you please clarify how fully matured loans and deposits should be presented in templates F05.01 and F08.01?

  • 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)

Treatment of Net Interest Income Stress Outlier Test (NII SOT) in scenarios where breaches occur due to one-off effects (EBA/RTS/2022/10)

Could you please provide guidance on how banks should approach the reporting of such NII SOT breaches arising from such short-term, non-structural events and in addition how is it foreseen that the regulator should govern such cases? Specifically, are there any provisions or considerations that can be applied to account for these temporary effects without misrepresenting the bank's overall NII sensitivity? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 530/2014 - RTS on materiality of thresholds for internal approaches to specific risk in the trading book

Counterparty classification

On FINREP reports, each counterparty is classified into a counterparty type, like Household or Government. Some government services are provided by volunteers, which raises the question how this should be classified, since the people are technically not employed by the government. Examples include volunteer police or volunteer firefighters and their unions, whose members provide and/or facilitate services specific to governments.

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

Validation rule v8821_m

The validation rule defines that in the event that column 020 of the template is valorised with the identification code indicating LEI code (eba_qCO:qx2000) then column 030 must be valorised with a LEI code.In reality, column 020 indicates the type of code to identify the third-party ICT service provider indicated in column 010. Consequently, shouldn't the validation rule be correct that the check should be made on column 010 and not 030?  

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

v16319_s and v16322_s (IRRBB) – non-negative rule not applicable to derivative rows

In line with the de-activation of v22331_s, we request to de-activate v16319_s and v16322_s as well

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

Template EU MR4 missing from Annex

The EBA Pillar 3 mapping tool mentions template EU MR4. I cannot find this in any of the annexes. Is this template relevant?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/11 - Guidelines on disclosure requirements under Part Eight of CRR

Definition of ‘subordinated liabilities’ for FINREP reporting

What should be considered as ‘subordinated liabilities’’ for financial reporting purposes in FINREP template 8.2? Does definition of “subordinated liabilities” include also MREL instruments that do not qualify as Common Equity Tier 1, Additional Tier 1 or Tier 2 items meaning and have characteristics defined in the Article 72b(2) of CRR? 

  • 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

Reporting aggregate exposure to shadow banking entities in CRR3

The newly introduced paragraph 2(b) in article 394 of CRR3 requires institutions to report as well the total Shadow Bank Exposure. This request is in addition to the top 10 such SBEs, already reported under CRR2, in line with paragraph 2(a) of the same article. Nonetheless the new ITS published under taxonomy v4.0, do not include any field which would allow us to report such information.   

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

Scaling of gross JTD amounts of securitisation tranches with a maturity less than one year

Should the tranche maturity (MT) of less than one year of gross JTD amounts of securitisation tranches resulting from either formula in Art. 257(1) CRR be floored at one year as required by para. 2 of this Article, or can the MT be used without this floor of one year in order to enable scaling, with a floor of three months, as prescribed by Art. 325z(5) CRR in conjunction with Art. 325x(3) CRR? 

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

Definition of Delta GIRR risk-free interest rate curves

Which risk-free interest rate curves per currency should be considered as different curves? 

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

Sign convention on EVE, NII and MV levels in Template J_01.00 and J_02.00

If the value of EVE,  NII and MV level in columns c0030, c0100, c0130 of template J_02.00 result in a negative sign, is it correct to input a positive sign in template J_01.00 for the same items as requested by the validation rules?

  • 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)

Exemption from approval for financial holding companies or mixed financial holding companies as per Directive 2013/36/EU (CRD) Article 21a (4) (d)

Should the criterion in Article 21a (4) (d) CRD (engagement in taking management, operational or financial decisions affecting the group or its subsidiaries) be considered to be met if the some persons are represented on the governing bodies of both the (mixed) financial holding company and an institution that is a subsidiary?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Level of EVE, NII and MV under Baseline scenarios reported positive for individual currencies (material or immaterial) in J1 report

Why is expected to always have the Level of EVE, NII and MV under Baseline scenarios reported positive for individual currencies (material or immaterial) in J1 report? Currently for the the rows of J1 report which reffer to Level of EVE, NII and MV under Baseline scenarios there is a validation rule (v16332_s) which throws a warning if the amount is negative regardless if the report is aggregated or for individual currencies. We believe this rule should be applied only for aggregated currencies and not for individual currencies as there could be a situation where the bank has a liability exposure in a specific currency which will end as a negative level of EVE/ NII or MV but when the aggregated report is obtained the final values are positive. Also, if the current rule is maintained, the results from J3 report will not be consistent with the ones from J1 as the negative amounts have to be reported positive. 

  • 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)