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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.

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List of Q&A's

Dropdown lists are invalid

Dear Sir/Madam  We have noticed that in the templates published by the EBA, the name manager reference for templates containing dropdown fields shows a #REF! error, causing the dropdown lists to be invalid. If possible, could you please provide us with the correct version of the template?  Kind Regards

  • 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: 2026_7718
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 27/02/2026

Deduction of goodwill included in the valuation of significant investments in entities included in prudential consolidation

For the purposes of calculating own funds on an individual basis and a sub-consolidated basis, are institutions subject to supervision on a consolidated basis required to deduct goodwill included in the valuation of significant investments of the institution, for holdings in such entities that are included in the scope of consolidated supervision?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7709
  • Topic: Own funds
  • 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.   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
  • ID: 2026_7693
  • Topic: Passporting and supervision of branches
  • Date of submission:
  • Published as Rejected Q&A: 17/02/2026

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
  • ID: 2026_7688
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 27/02/2026

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
  • ID: 2026_7687
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 26/01/2026

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
  • ID: 2026_7685
  • Topic: Internal governance
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2026

Alternative treatment and SME support factor

If an institution uses the alternative treatment i CRR3 article 230 (4), does the exposure then qualify to use the SME supporting factor?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7682
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/01/2026

I couldn´t find this question.

We request EBA’s clarification on the application of Article 402 CRR to exposures fully secured by commercial property classified as IPRE under CRR III, but risk‑weighted as non‑IPRE in accordance with the exemption defined in Article 126(2) because the property meets the national conditions applicable in Sweden (the so‑called “hard test”). Specifically: 2.1 Eligibility for Article 402 when collateral is IPRE by classificationDoes the collateral’s IPRE classification affect eligibility for the Article 402 exposure value reduction, specifically for large exposures where the risk-weighting due to the exemption in Article 126(2) is treated as non-IPRE due to national conditions in Sweden (the so-called “hard test”) 2.2 Treatment under Swedish national conditionsIn cases where national authorities allow commercial IPRE collateral to be risk-weighted as non-IPRE under Article 126(2) (Swedish hard test), can the bank apply the Article 402 reduction, assuming all CRM requirements under Articles 399, 208, and 229 are satisfied? In other words: Does Article 402 eligibility follow the risk-weighting treatment under Article 126.2, or does it follow the classification of the collateral under CRR III?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7670
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 13/01/2026

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

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

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

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

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

COREP C14.00, columns 0140-0225, validation rules v11650_m, v11651_m and v7347_m

Pursuant to para (a) of the definition of originator, the submitter qualifies as the sole originator as an entity which itself or through related entities, directly or indirectly, was involved in the original agreements which created the obligations of the debtors giving rise to the exposures being securitized.  The securitized exposures/obligations were not on the submitter’s balance sheet.  However, given the definition of originator (in particular para (a)) we understand that the presence of the securitized exposures/obligations on an entity’s balance sheet, is not a condition for such entity to qualify as an originator (including as the sole originator). We further understand that in the templates C14.00, the section securitized exposures, columns 0140-0225: apply to an originator of securitization positions which were securitized from such originator’s own balance sheet (‘own portfolio’); do not apply to an originator where the securitization positions were not on such originator’s own balance sheet. If our understanding is correct, please confirm that the submitter, as a sole originator which did not have the securitized exposures/obligations on its balance sheet, should not be required to populate section Securitised Exposures, columns 0140-0225?

  • 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_7643
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 18/02/2026

Deduction of participations and Corep reporting

For the deduction under article 17 (1)(e), of RTS 241/2014, what is the correct COREP row for reporting this item? Is reporting under row 0529 “CET1 capital elements or deductions – other” appropriate? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions
  • ID: 2025_7642
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2026