Search for Q&As

Enquirers can use various factors to search for a Q&A:

  • These include searching by the Q&A ID; legal reference, date submitted, technical standard / guideline, or by keyword if known.
  • Searches can be extended to more than one legal act, topic, technical standard or guidelines by making multiple selections (i.e. pressing 'Ctrl' on your keyboard, and selecting the relevant ones from the drop-down lists by left mouse-click).

Disclaimer:

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.

Final Q&As Q&As under review Rejected Q&As Archived Q&As All Q&As

List of Q&A's

Definition of financial institution under Article 4(1)(26)

Does the definition of financial institution under Article 4(1)(26) CRR include trust companies under Liechtenstein law?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7300
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 21/01/2025

Definition of ancillary services undertaking under Article 4(1)(18)

Does the definition of ancillary services undertaking under Article 4(1)(18) CRR include trust companies under Liechtenstein law?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7299
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 21/01/2025

Remittance date for quarterly iMREL/iTLAC Q1 2025

Will the remittance date for Q1 2025 iMREL/iTLAC reporting be aligned to the due date for COREP reporting for which the submission date is postponed to June 2025?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/763 – ITS with regard to the supervisory reporting and public disclosure of MREL
  • ID: 2025_7298
  • Topic: MREL
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2025

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)
  • ID: 2024_7289
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2025

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)
  • ID: 2024_7287
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2025

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

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

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

Reporting of ESCROW accounts (or other captive accounts) in template F08.01

In which row shall be reported Escrow accounts (or other captive deposits) from non financial companies in template F 08.01 ‘Breakdown of financial liabilities by product and by counterparty sector’?  Either as being ‘Current accounts/overnights deposits’ row 0270 or as ‘Deposits redeemable at notice’ row 0290 or as ‘Deposits with agreed maturity’ row 0280?  

  • 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_7262
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 09/01/2025

Equity instrument subject to impairment in F20.04

The instructions for reporting the column "of which: financial assets subject to impairment [...]" regarding equity instruments (see F20.04 r0040 c0012) currently leave room for interpretation about the specific definition of "subject to impairment" to be applied. In particular, we would kindly ask the EBA to clarify whether a) the respective positions should be deactivated (i.e., greyed out) because of non-applicabilityb) there is a different expectation regarding equity instruments that has not been written in the Annex yet (in particular, equity instruments are subject to the IAS 36 impairment test).

  • 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_7258
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 09/01/2025

NACE sector K- 'Financial and insurance activities' in F 06.01

Can EBA confirm that Holding companies, as defined in ESA 2010, are out of scope of template F06.01? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7245
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 13/01/2025

Should repricing coupons be included in J06 sheets?

Should repricing coupons be included in J06 sheets in IRRBB reporting? EBA’s validation formula says that repricing coupons should not be included (validation rules v22320_m and v_22321_m). Otherwise the regulation (Final Draft RTS on Standardised Methodologies on IRRBB, Article 1, “’Notional repricing cash flow’ means: (c) Any interest payment on a part of the principal that has not yet been repaid or repriced) says that repricing coupons should be included. And if those repricing coupons are included (as the regulation says) it will cause validation rules v22320_m and v22321_m to be active because repricing notionals are always greater than the notional only.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7244
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 28/11/2024

FINREP Templates F25 and F13

It has come to our attention that Form F25.01.a contains data elements that overlap with Form F13.3.1. For instance, F25.01.a Row 0120 Column 0030 shares data with F13.3.1a Row 0020 Column 0010. From a business perspective, this inclusion appears incongruous, and we would appreciate an explanation of the rationale behind this decision. Could you please provide the logic and reasoning for including this shared data element between Form F25 and Form F13?

  • 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_7240
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 28/11/2024

Reporting Requirements on exposures subject to behavioural modelling

What is expected to be reported on the template J08.00b in terms of the perimeter of exposures included in the reporting of relevant parameters? Only those exposures actually subject to behavioural modelling by the institution (thus excluding exposures exposed to Prepayment, NMD behavioural modelling and Early Redemption Risks but non modelled by the institution) or all the exposures exposed to such risks, including those on which models are not applied?

  • 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_7239
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 28/11/2024

Aggregated method for duration of derivatives

Could the EBA please clarify the expected method to aggregate and report the Duration value (column 0020) in template J 02.00 for derivatives?

  • 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_7238
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 28/11/2024

Seniority categories to use when offsetting the gross JTD amounts of short exposures and long exposures within the DRC calculations for non-securitisations 

Which set of seniority categories shall be utilised and how should they be ranked as the basis for offsetting the gross JTD amounts of short exposures and long exposures within the DRC calculations for non-securitisations? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7233
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 17/01/2025

Vega general interest rate risk and credit spread risk factors

For credit instruments that include issuer-specific optionality, do both general interest rate vega and credit spread vega risk factors need to be considered as part of the SBM? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7232
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 17/01/2025

Basis of calculation for the DRC for non-securitisations and SBM-CSR for non-securitisations - instruments guaranteed by a guarantor

In the case of instruments guaranteed by a guarantor (such as guaranteed bonds), can that guarantor be used as the basis for calculating the DRC for non-securitisations and the SBM-CSR for non-securitisations? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7231
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 17/01/2025

Basis of calculation for the DRC for non-securitisations and SBM-CSR for non-securitisations – Individual ‘issuers’/‘obligors’ or ‘group of issuers/obligors’?

Do the calculations of the DRC for non-securitisations and SBM-CSR for non-securitisations have to be based on the individual ‘issuers’/‘obligors’, or could these calculations alternatively be based on the concept of a ‘group of issuers/obligors’ consisting of e.g. a conglomerate (and e.g. represented by an ‘ultimate parent’ corresponding to the ‘head of group’ or ‘parent company’)?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7230
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 17/01/2025

Conditions for increasing the margin period of risk (MPOR) used for the exposure value of netting sets with margin agreements.

Article 285 paragraph 3(b) references “OTC derivative that cannot be easily replaced”. By definition “OTC derivative” does not include listed / exchange trades derivatives.  The final sentence of paragraph 3 states “An institution shall consider whether trades or securities it holds as collateral are concentrated in a particular counterparty and if that counterparty exited the market precipitously whether the institution would be able to replace those trades or securities.” Is this is a clarification of 3(b) meaning that the reference to “replace those trades” would be in relation to OTC derivatives? Or alternatively is the reference to “replace those trades” broader than OTC derivatives?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7229
  • Topic: Market risk
  • Date of submission: