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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

CCF of items (b) and (c) of bucket 5 from 2025 to 2032

Which credit conversion factor shall be applied to the undrawn amount of retail credit lines for which the terms permit the institution to cancel them to the full extent allowable under consumer protection and related legal acts (item listed in point (b) of bucket 5), and to undrawn credit facilities for tender and performance guarantees which may be cancelled unconditionally at any time without prior notice, or that do effectively provide for automatic cancellation due to deterioration in a borrower’s creditworthiness (item listed in point (c) of bucket 5) in the years 2025 to 2032?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7318
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 23/04/2025

Minimum monetary amount of professional indemnity insurance in ongoing supervision

Are points 5.4, 5.7, 5.10 and 7.4 of EBA/GL/2017/08 guideline applicable only while applying for authorisation or in ongoing supervision as well? Is 50 000 per indicator minimal amount after authorisation procedure/first year as well?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/08 - Guidelines on the criteria on how to stipulate the minimum monetary amount of the professional indemnity insurance
  • ID: 2025_7317
  • Topic: Monetary amount of the professional indemnity insurance
  • Date of submission:

Counterparty classification of CCP

Where counterparty sector breakdown applies, it is required more guidance on how to classify a CCP which have the banking license. For instance, in template F10, where should we report derivatives positions we have with a QCCP which at the same time is (i) a clearing house and (ii) a credit institution (included in the list of ECB’s supervised banks)? We face the ambiguity in classification in further reporting frameworks both supranational (e.g. G-SIB data collection exercise, FSB)  and local (i.e. Circolare 262 Banca d’Italia on Financial Statements).

  • 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_7316
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/03/2025

RWA in COREP C43

In COREP C43, which RWA should be reported? In particular, should RWA be reported with or without taking into account the derogations (transitional measures) impacting RWA in CRR3?

  • 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_7315
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as Rejected Q&A: 28/04/2025

C01.00 - CIU deduction from own funds

Where in the sheet C01.00 of the COREP, can we deduct CIUs under fallback approach (subject to 1250% RWA) from CET1 (as permitted by article 36.1.k.vi) since no dedicated caption is currently foreseen?

  • 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_7314
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 21/03/2025

Part 2 – Template specific instructions to template B_06.01

Data point B_06.01.0050 is missing from the official ITS templates. Is this data point no longer applicable?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information
  • ID: 2025_7313
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as final Q&A: 28/03/2025

DPM 400 - Modelisation of report C1000

we have a suspicion of schizophrenic modeling on the new C1000 report.  Indeed on this report when we look at the annotated templates it seems that all cells from column 0090 are sharing the same XBRL address as their corresponding cell for the same row from column 0100. Which means that from a technical point of view we will only be able to submit one “amount” per pair of cells C0090/C0100 for a dedicated row. For instance the Annotated templates stats that : {C_10.00, r0060, c 0090, s0000}=={C_10.00, r0060, c 0100, s0000} VariableID 3295841 VariableVID = 3295841    In the same time when we look at the ITS : We understand that may be possible that the transitional provisions do not apply  and so that or instance amount reported in cell 0020 _ 0090 can be equal to the amount in cell  0020 _ 0100 where the amount expected  for both cell is zero.  But we do expect from our understanding of the ITS that the transitional provision may apply and that the impact should be reported in various rows. In this case we will need to report different amounts on a specific row for those two columns, which seems unfeasible with the current setting.   Do you agree with our understanding?    

  • 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_7312
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 21/03/2025

Regulatory technical standards - subcontracting ICT services supporting critical or important functions

Where and when was the Comission Delegated Regulation (EU) supplementing Regulation (EU) 2022/2554 of the European Parliament and of the Council with regard to regulatory technical standards to specify the elements which a financial entity needs to determine and assess when subcontracting ICT services supporting critical or important functions as mandated by Article 30(5) of Regulation (EU) 2022/2554 oficially published? 

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7310
  • Topic: Other DORA topics
  • Date of submission:
  • Published as Rejected Q&A: 17/03/2025

Validation rule v22095_h in Reporting Framework 3.5

The question concerns the EBA Reporting Framework 3.5, Validation Rules (19 December 2024), rule v22095_h. This rule require that total amounts of Loans and Advances should be equal to the sum of sub-total amounts (Retail, Wholesale non-financial, Wholesale financial) in the context of Reporting on interest rate risk in the banking (specified in Section 12 – ‘Reporting on interest rate risk in the banking book’ of Annex I to Regulation (EU) 2024/3117, form J02.00 : {r0050} = +{r0080} + {r0100} + {r0110}Is the formula correct having in mind the possibility to have exposures from clients that do not satisfy definitions of sub-categories but have to be reported in "Loans and Advances"? 

  • 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_7308
  • Topic: Supervisory reporting - IRRBB
  • Date of submission:
  • Published as Rejected Q&A: 28/04/2025

Computation of the secured part of Non-IPRE according to Art.125(1)

In the computation of the secured part of Non-IPRE exposures, should senior liens from banks within the same group be taken into account?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7305
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 21/02/2025

Internal Model Method

What is the prudential treatment of cash flow spikes in the calculation of own funds requirements for counterparty credit risk under the Internal Model Method?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7303
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 21/05/2025

Treatment of feature of tranching for mortgage backed securities

With regards to agencies pools and TBAs, since these are not really tranche product because they are backed by the US government, should they be considered more like a non securitized product rather than securitized product under the SBA?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1423/2013 - ITS on disclosure of own funds requirements
  • ID: 2025_7302
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 17/02/2025

Other commitments received - calculation of guarantee amounts

On report F09.02, banks are asked to report guarantees received as collateral, partly in column 0010 and partly in column 0020. Where some questions have been answered in earlier Q&As, some questions remain: Based on Q&A 2013_214, guarantees received on off-balance sheet exposures should be reported as "Other Commitments Received". These are reported in F09.02 Col0020.Based on Q&A 2023_6773, in F09.02 Col0010, guarantees are considered by ignoring other collaterals.Should other collaterals be considered in calculating the amount reported in column 0020? Along the same lines, how should calculations work for both columns 0010 and 0020 if multiple guarantees are received? Within the same group of exposures and its/their contractually linked collaterals/guarantees, should they all be calculated separately and independently, ignoring the existence of other guarantees within the same group similar to the way other collaterals in the same group are ignored?The ITS states that "For other commitments received, the nominal amount shall be the total amount committed by the other party in the transaction." is to be reported in column 0020.  Does this also apply in the case whereby a guarantee is received to secure an (off-balance) exposures? In other words, should it be capped at the Off-Balance Exposure Amount or not?

  • 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_7301
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/03/2025

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

The scope of the regulation described in Article 6 mismatches what is presented as an option in the Annex I, Part 2 of the same regulation

Do financial entities must include non-financial entities within the same group in the Register of Information? If not, why is there an option to do so?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information
  • ID: 2025_7297
  • Topic: Register of information (DORA)
  • Date of submission:

Validation Rule for Marginal Impact of Reintegration of CVA Exemptions

The guidance for the population of rows 0040-0110 specifies that firms should populate the marginal impact of reintegration of CVA exemptions "separately for each exemption". However there is a warning validation rule v23083_m which specifies that the sum of the individual exemptions should be equal to the total "{r0040} = {r0050} + {r0060} + {r0090} + {r0100} + {r0110}". We would like to query whether the validation rule is valid and therefore whether we should be calculating a single CVA exemption reintegration impact of excluded transactions and then attributing by type of exemption or genuinely calculating the marginal impact separately by type of exemption. 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2025_7295
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 26/02/2025

Requirements for the purpose of treating exposures secured by mortgages on immovable property as duly secured from an RWA computation perspective under CRR Article 124(2) of the CRR.

Can a global insurance against damages on a portfolio of exposures secured by immovable properties subscribed directly by the lending institution be considered as compliant with the requirement of Article 208(5) of the CRR - that is to say considered, under the standardized approach, as meeting the operational requirements for the purpose of treating exposures secured by mortgages on immovable property (or in case an institution has opted for the application of article 108(5)(a) allowing to consider a guaranteed exposure as an exposure secured by a mortgage on immovable property) as duly secured from an RWA computation perspective under Article 124(2) of the CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7293
  • Topic: Credit risk
  • Date of submission:

Clarifications on the perimeter of templates 2 and 5 Collateralized loans portfolio

The Bank would like to clarify whether the same perimeter should be applied in ESG Pillar 3 Templates 2 and 5 regarding loans collateralized by residential/commercial property in column 010 (Gross Carrying Amount). Specifically, Template 2 requires banks to disclose the energy efficiency of the collateral for loans secured by immovable property, including cases where the Energy Performance Certificate (EPC) is available or unavailable, with the percentage of estimated EPCs provided when the certificate is unavailable. Based on this guidance, it seems that Template 2 would include only assets eligible for Energy Performance Certification as per relative legislation, as EPCs cannot be defined for non-eligible assets. In contrast, Template 5 would appear to cover both EPC-eligible and non-eligible assets. It would be helpful to understand if this interpretation aligns with the intended approach and whether column 010 of Template 2 should specifically reflect the subset of loans collateralized by residential/commercial property that are eligible for EPC.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2025_7292
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 28/04/2025