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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

Validation rule v7511

validation rule v7511m Z_03.01, c, default: 0, interval: true}: {r0400} = {r0410} + {r0420} + {r0430} + max({r0440}, {r0450}, does not seem to be complete as it does not consider Z0.3.01 r0460

  • 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_7828
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Templates Z07.01.2 - Timing of substitution for Lending

Please confirm the time buckets to be used for reporting col 0130 'Timing of Substitution' in template Z07.01.02 FUNC1 Lending

  • 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_7827
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Templates Z9.03 - Null values reportable in col 0020 Segment

Please confirm what should be populated in Template 9.03 col 0020 Segment as the taxonomy does not allow null values whereas Annex II instructions specify this should be reported for CCPs only.

  • 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_7826
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Templates Z09.02 - 'Country 0030 ' and 'Critical functions ID 0040' for Essential FMIs

Please confirm what should firms populate in Template 9.02 columns 'Country 0030 ' and 'Critical functions ID 0040' for non-critical FMIs as these columns cannot have null values.

  • 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_7825
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Templates Z09.01 - Services provided to and received from FMI/Intermediary

Could the EBA please confirm instruction interpretation for col 0220 and Col0210 of Template 09.01 (FMI Services - Providers and Users).

  • 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_7824
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 09/10/2026

Template Z09.01: EBA Taxonomy alignment with ITS Requirements -Annex II instructions

Does the EBA taxonomy need to be updated to allow column 0110 of template Z09.01 to be left null when col 0090 is 'Direct', consistent with the Annex II instructions?

  • 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_7823
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 09/10/2026

Template Z08.01: Reporting on intra-group services with identical LEI codes

Per EBA taxonomy, concatenation of col 0005, 0010, 0020, 0040, 0060 and 0130 in Template 8.01 should be unique (unique key).  This causes duplication error across rows reporting similar intra-entity services between different branches, i.e. identical providers/receiver codes and identical other fields required for unique key.Does the taxonomy need to be amended to allow such reporting?

  • 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_7822
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

incoherent formulae

The formula of control v90322_m seems not relevant.

  • 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: 2026_7821
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

When trying to submit reports to our portal Finanssivalvonta it gives us this error: An error occurred while converting CSV to XML. Error while reading CSV instance: error:unresolvableBaseMetadataFile ; : The resource "http://www.eba.europa.eu/eu/fr/xbrl/crr/fws/corep/4.2/mod/corep_of.json" is missing

When trying to submit reports to our portal Finanssivalvonta it gives us this error:     An error occurred while converting CSV to XML. Error while reading CSV instance: error:unresolvableBaseMetadataFile ; : The resource "http://www.eba.europa.eu/eu/fr/xbrl/crr/fws/corep/4.2/mod/corep_of.json" is missing. What does this mean? we cant seem to figure that out

  • Legal act: Other
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7820
  • Topic: Not applicable
  • Date of submission:
  • Published as Rejected Q&A: 29/05/2026

Pillar 3 Transparency - Risk weight missing in Template CCR3

Values with risk weight 30% are not allocated (according to the EBA Mapping Tool) to template CCR3, although these values appear in Row 185 of template COROFC C07.00. Is it intended to exclude values with 30% risk weight from template CCR3 (if yes, please provide the reasons for that) or is this a bug in die EBA mapping tool?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7819
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 11/05/2026

Definition of "official export credit agency" for the calculation of deduction for non-performing exposures

Article 47c(4a) of the CRR exempts the part of a non‑performing exposure guaranteed or insured by an “official export credit agency” (ECA) from the deduction requirements laid down in Article 47c. However, the CRR does not define the term “official export credit agency”. In this context, what are the criteria for qualifying as an “official export credit agency” and how can it be determined whether an export credit agency and the guarantee or insurance provided meets the criteria for applying the derogation as provided in CRR Article 47c(4a)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7818
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 12/05/2026

Reporting of certain counterparty identifiers in templates Z 12.00 and Z 14.00

How should entities report the identifier and the type of identifier when reporting at an aggregate level or when the counterparty is unknown?

  • 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_7815
  • Topic: Resolution plans
  • Date of submission:
  • Published as final Q&A: 09/10/2026

Z 09.02 (FMI2) FMI services reporting criteria

Could the EBA confirm the correct reporting criteria for columns 0040 (Critical Function ID) and 0060 (Core Business Line ID) in template Z 09.02 when an FMI is classified as either essential or critical, but not both, and the procedure to follow when an FMI maps to multiple functions or business lines?

  • 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_7814
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

Concerns on reporting on all relationships between investor and investee in Z01.02 of RESOL1 in alignment with the indication of key value as marked in the DPM 4.2 module

How to report correctly on the relationship of the investor (Z01.02, column 0020 “Code”) and the investee (Z01.02, column 0050 “Code”) when the investor invests in multiple investees? Could you please adjust the technical requirements stated in the Annotated Table Layout in the DPM 4.2 module (20260106 Annotated Table Layout RES 4.2 RESOL1RES 4.2.xls) and apply the setting of ‘Key value’ to both column 0020 as well as to column 0050?

  • 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_7813
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

Disclosure – Template EU CQ4: Treatment of cash balances at central banks and other demand deposits

Should cash balances at central banks and other demand deposits be included in disclosure template EU CQ4 as provided in the EBA IT Solutions / Mapping Tool (versions 4.1 and 4.2) even though such positions are not mentioned in Article 442(c) and (e) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR
  • ID: 2026_7812
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 05/06/2026

Historical valuation series considered in determining the average value of real estate collateral

Considering that institutions may rely on comparable real estate valuation indices to fill in periods where no formal property revaluation exists, in order to construct the required equally distant interval valuation points, is there any requirement or expectation to extend the historical series beyond the minimum three data points, covering the full reference period (e.g., six years for RRE and eight years for CRE)?  The reasoning underlying this question is illustrated in the following example: RRE: Case 1 - Exclusive reliance on three data points derived from formal property revaluation exercises Period 0: Property value at origination Period 1: -- Period 2: -- Period 3: First formal property revaluation Period 4: -- Period 5: -- Period 6: Second formal property revaluation RRE: Case 2 - Use of real‑estate price valuation indices to construct the historical period Period 0: Property value at origination Period 1: First property value collected using real‑estate valuation indices Period 2: Second property value collected using real‑estate valuation indices Period 3: Third property value collected using real‑estate valuation indices Period 4: Fourth property value collected using real‑estate valuation indices Period 5: Fifth property value collected using real‑estate valuation indices Period 6: First formal property revaluation RRE: Case 3 - Use of real‑estate price valuation and indices to construct the historical period Period 0: Property value at origination Period 1: First formal property revaluation Period 2: First property value collected using real‑estate valuation indices Period 3: Second property value collected using real‑estate valuation indices Period 4: Third property value collected using real‑estate valuation indices Period 5: Fourth property value collected using real‑estate valuation indices Period 6: Second formal property revaluation

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7810
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Application of the current market value as a cap for immovable property collateral

Should the most recent market value constitute the maximum permissible (“cap”) for prudential purposes, even when the revaluation mechanisms under Article 229 would otherwise yield a higher value?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7809
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Unique values in Z.01.02 in column 0020

How are institutions expected to report repeated values in column 0020 of template Z 01.02?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on the provision of information for the purpose of resolution plans
  • ID: 2026_7808
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

Clarification on validation v3078m under FINREP reporting

In reference to the validation rule 'v3078_m' should the held for trading positions be excluded while reporting the maximum amount of the guarantee received in FINREP F_09.02

  • 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: 2026_7807
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/06/2026

Application of Article 199(6)(d) for low default portfolios

In cases where institutions do not have a sufficient internal track record of default and liquidation events due to the low-default nature of certain portfolios, is there an alternative approach, such as the use of relevant external data, market evidence, or a combination of internal and external information, that could be considered acceptable to demonstrate compliance with Article 199(6)(d) for eligible physical collateral?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7806
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/05/2026