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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

Z 09.01 – FMI Services – providers and users (RESOL2)

We ask confirmation that the column “0140-Resolution resilient contract” applies only in the case of indirect access to FMIs and that for FMIs with direct access, the value “Yes” should be reported

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Reporting of the penalty fees in J07.00 Repricing cash flows (behavioural template)

How should the penalty fees be treated in J07.00 Repricing cash flows (behavioural) template? At this point, the inclusion of penalty fees will break the validation rule v22322_m.

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

DPM 4.2 on SERV Template (Z.08.04)

We are writing to request a clarification regarding the latest DPM update dated 13 January, with specific reference to Template Z8.04.In the current version, the “Critical Function - ID” field (column 0040) is not included among the key fields. However, in Template Z8.05, the “Business Line ID” is defined as a key field.This difference creates a reporting challenge for us. A single service, identified by a unique Service Identifier, may support more than one critical function. If the “Critical Function” field is not part of the key, it is not possible to link multiple critical functions to the same service within the template.As a result, we would need to create multiple Service Identifiers for the same service, leading to an increased number of records across other templates, including Template Z8.01.Could you please confirm whether the exclusion of the “Critical Function - ID” from the key fields in Template Z8.04 reflects the intended approach?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Resolution Reporting on FMI

With reference to Resolution Reporting on FMI Services, we would like to bring to your attention some questions regarding the scope and data reported, particularly in cases where the Bank participates indirectly in certain FMIs. With reference to item "Z 09.03 - Financial Market Infrastructure Services (FMI) - Key Metrics (FMI 3)", we would therefore like to know whether, for FMIs to which we participate indirectly, it is possible to report intermediary data instead of individual FMI data, and, if so, how to complete the individual items. The question specifically concerns the following reporting fields: • Z 09.03/60-70 Value of positions on proprietary and client accounts • Z 09.03/80 Number of clients covered by omnibus accounts • Z 09.03/90 Number of clients covered by segregated accounts • Z 09.03/100-110 Number of transactions on proprietary and client accounts • Z 09.03/120-130 Value of transactions on proprietary and client accounts This requirement arises from the fact that, since we use an intermediary, we do not have internal evidence of the final FMIs on which it relies. In fact, our systems only map the intermediary's reference, while the references of the final FMIs are not tracked. As an example, we can cite Intesa San Paolo, which acts as an intermediary for Banca Mediolanum on all CSDs and most trading venues. In our systems, Intesa San Paolo is matched to all securities transactions, without specifying the final CSD. We currently report that we are still providing the above-mentioned information by requesting detailed data from our intermediaries. In this regard, we also note that our intermediaries will include our data in their reporting for individual FMIs, reporting us as their clients in these contexts.   Finally, we would like to take this opportunity to request clarification regarding some new items introduced starting this year, specifically: • Z 09.01/80 Operator of the FMI - is it correct to indicate the contractual contact person of the FMI/Intermediary? • Z 09.04/20 Product Type - Is it possible to include a description of the service provided by the FMI/intermediary, consistent with that indicated in item Z 09.01/220 - Services provided by FMI/intermediary, possibly with greater detail? • Z 09.04/30 Substitutability - Should the substitutability analysis be performed for all FMIs, considering as alternative FMIs/intermediaries only those with which a contract at the conglomerate level is already in place?  

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Incorporation of historical data from integrated entities when historical information is not representative of current underwriting standards

Should an institution incorporate historical default data from acquired or merged entities into its IRB model estimates for PD, LGD, and CCF when calculating RWA for the acquiring institution’s exposures originated before and after the merger? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/16 - Guidelines on PD estimation, LGD estimation and the treatment of defaulted exposures

C.08.01 - VariableVID 3293070 - Identical cells

Should the identical cell rule with VariableVID equal to 3293070 be applicable to C08.01?

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

EBA mapping file for Pillar 3 template EU CMS2

The mapping file for EU CMS2 template seems to contain multiple issues: 1) The Naming of the row EU 7a does not conform to the regulation 2024/3172 (ITS). In the ITS, the row is not an ‘of which’ row, but an independent row. 2) The row 6.2 (Of which: Retail - Secured by residential real estate) appears to be redundant. Following the ITS instructions for this section, “Where the IRB exposures would have been allocated in a different exposure class in the standardised approach (SA), the IRB exposures shall be excluded from their IRB exposure classes and they shall be disclosed   in one of the following exposure classes of the Standardised approach”. All exposures (partially) secured by real estate must be disclosed on row EU 7a or EU 7c , no exposure can be disclosed on row 6.2, which is an ‘of which’ category of row 6 (Retail). The mapping to COREP C10 row 0170 appears incorrect as it conflicts with the ITS instruction to reclass the exposures.  

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

Z02.00_r0334 sum of net liability positions taking into account prudential netting rules

In accordance with Articles 429 and 295 of the CRR, only netting agreements that are legally recognised are eligible for consideration under prudential netting rules. With regard to standalone derivative positions that represent liabilities and are not subject to any netting agreement, is it correct to report these in r0334, even though they cannot be netted under the prudential netting framework?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Encumbrance reporting treatment of surplus assets in a cover pool

Can surplus assets within a covered bond pool that are economically available to the issuer and above minimum over-collateralisation requirements (regulatory, contractual and what is required by the rating agencies to maintain the rating) be reported as unencumbered where they are subject only to an operational process for withdrawal?

  • 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

Validation Rules

Validation rule V89101_S (with {tK_19.02.a, c*, default: null, interval: false}: {(r0040, r0090)} <= 0) of the Pillar 3 template EU OR2: it appears that the two rows “1b. Interest and lease expense” and “2b. Fee and commission expense” have to be reported with the negative sign or as zero. We guess that these two rows should be reported as positive or zero, because of the following reasons: It is already known, by definition, that they are “expenses”. This validation rule is not extended to the row “2d. Other operating expense”. Considering the DPM 4.2, which will enter into force from Q1 2026, the Validation Rules v903192_s (with {tC_16.02, c0070, default: null, interval: false}: {(r0010, r0110, r0200, r0220, r0260, r0310, r0340, r0370, r0420)} >= 0) and v903193_s (with {tC_16.02, default: null, interval: false}: {(r0020, r0030, r0040, r0050, r0060, r0070, r0080, r0090, r0100, r0120, r0130, r0140, r0150, r0160, r0170, r0180, r0190, r0210, r0230, r0240, r0250, r0270, r0290, r0300, r0320, r0330, r0350, r0360), (c0010, c0030, c0050)} >= 0) of the CoRep template C16.02 appear to require that all the expenses related items have to be reported with positive sign or as zero. Considering the mapping tool provided within the EBA Consultation Paper of February 2024 on OpRisk disclosure (file “mapping_tool_for_crr_3-step1-oprisk_tc.xlsx”), for the part related to the Pillar 3 template EU OR2, a direct link was reported to the related cells of the CoRep template C16.02, which were required to be positive by the Validation Rules reported at the previous point. In the Quantitative Impact Study (QIS), performed semi-annually by the Basel Committee, the sheet “OpRisk” requires reporting the items “Interest expenses (including financial and operational lease)”, “Fee and commission expenses”, and “Other operating expenses (except for financial and operational lease)” with a positive sign or as zero.   Validation rule V89104_S (with {tK_19.02.b, c0050, default: null, interval: false}: {r0190-0200} <= 0) of the Pillar 3 template EU OR2: it appears that the items “6b. Reduction in BI due to excluded divested activities” and “6c. Impact in BI of mergers/acquisitions” have to be lower than or equal to zero. We guess that the items “6b. Reduction in BI due to excluded divested activities” and “6c. Impact in BI of mergers/acquisitions” should be reported as zero or positive for the following reasons: It is already known, by definition, that item 6b is a “reduction”. Item 6c, i.e., the impact of an M&A operation, is generally positive. Considering the DPM 4.2, which will enter into force from Q1 2026, there are no Validation Rules that require reporting the columns 0020 (“of which: adjustments due to merge/acquisition of entities or activities”) and 0030 (“(Adjustments due to disposal of entities or activities)”) with a negative sign or as zero. Considering the mapping tool provided within the EBA Consultation Paper of February 2024 on OpRisk disclosure (file “mapping_tool_for_crr_3-step1-oprisk_tc.xlsx”), for the part related to the Pillar 3 template EU OR2, a direct link was reported to the related cells of the CoRep template C16.01, where the item 6b has to be “'={C 16.01, r0020, c0030}” (“Business indicator” / “(Adjustments due to disposal of entities or activities)”) and the item 6c has to be “={C 16.01, r0020, c0020}” (“Business indicator” / “of which: adjustments due to merge/acquisition of entities or activities”). Considering the previous point, no Validation Rules are coming from the CoRep template C16.01. In the Quantitative Impact Study (QIS), performed semi-annually by the Basel Committee, in the sheet “OpRisk,” the item “Reduction in BI due to excluded divested activities” is reported with a positive sign or as zero.

  • 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 4.2 Resolution Planning reporting Template Z12 Treatment of the “Instrument Type” field

With reference to the DPM 4.2 Resolution Planning reporting framework and, in particular, to Resolution Plan Template Z12, field “Type of instrument”, could you confirm the correct classification of the instruments listed below under the Italian jurisdiction for reporting 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

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.   A TCB is often invited with an invitation letter sent by one or several commercial banks or investment banks (known as arrangers) in different Member States, to provide loans together with a group of lenders domiciled in various Member States for a borrower or a borrower group that might operate in several Member States. The TCB as a lender does not have direct contact with the borrower. The invitation letter is sent by the arranger bank to invite the TCB to provide a portion of the loan for the borrower. Is the invitation letter sent by the arranger a sufficient supporting document to evidence that a client approaches us through an arranger at its own exclusive initiative? If not, is an independent statement from the borrower to certify that it has approached the TCB through an arranger adequate?   

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

DPM 4.2 – Correctness of identical cells between C 25.01.a and K 60.00

For DPM 4.2 the cells {C_25.01.a, r0010, c0020} and {K_60.00.a, r0120, c0030} are identified as identical, have the same assigned VariableID and the same defining DPM properties. Considering the instructions for reporting data in these cells different values are expected.

  • 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

Z08.01 & Z08.02: Resolution resilience reporting

Should the explicit inclusion of clauses referred to in data points c0150 to c0170 of Z08.01-Template and c0100 to c0120 of Z08.02-Template be required only for contracts governed by third-country law, considering that contracts governed by EU law are deemed resolution-resilient by virtue of the implementation of BRRD requirements in the national legislation of Member States?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Type of exposures to report on r0152 of C10.00 COREP Template

Considering the scope of the row 0152 on C10.00 template, does the exposures that should be reported refer to UNSECURED exposures?

  • 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

US Hard test: adequacy of considering US charge-off rates corresponding to loss rates for exposures secured by residential property or commercial immovable property situated within the territory of the US

May institutions in accordance with Article 199 (4a) of Regulation (EU) No 575/2013 (CRR) apply the derogations  from point (b) of paragraph 2 of Article 199 CRR, as referred to in paragraphs 3 and 4 of Article 199 CRR, for residential / commercial immovable property situated within the territory of the US, based on (adjusted) US charge-off rates as published by the Board of Governors of the Federal Reserve System (US), retrieved from FRED, Federal Reserve Bank of St. Louis? 

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

Use of short-term issuer credit assessments under Article 131

May short-term issuer ratings be used to derive risk weights for unrated short-term exposures in the context of Article 131 CRR?

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

Discrepancies between taxonomy packages

Can you please provide clarity on whether or not the identified differences between ECB's SFRDP taxonomy 5.2 and EBA's FINREP9_DP in DPM 4.2 will be addressed /aligned in a future DPM publication, or if these are intentional and will remain as they are in DPM 4.2? If they will be aligned, please indicate when this can be expected.

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

Question regarding minimum requirements for Risk Committee attendance

Is there a minimum number of administrators required to be present for a risk committee dedicated to internal control to validly hold its meetings ? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/05 - Guidelines on internal governance under CRD - repealing EBA/GL/2017/11

Validation rule v5702_s (F 31.01)

We request a change in the status of validation rule number v5702_s from 'Error' to 'Warning' in the consolidated FINREP ITS report. 

  • 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