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List of Q&A's

Requirements of Z 11.00 for RLE that are not institutions

Article 3 - Group resolution reporting  We observed some differences, especially for the Z 11.00 template when comparing the 2 parts of the final draft below: the draft proposal to the commission (chapter 3 Draft Implementing Technical Standards, article 3) and the tab in accompanying documents (chapter 2 Background and rationale - 2.2.4 Overview of revised reporting obligations). It seems there is no article requiring specifically from RLEs that are institutions to report Z 11.00 template, although it is included in the tab "Overview of revised reporting obligations". The Z 11.00 template is mentioned in paragraph 7, which seems to either concern the resolution entity or the scope of the article seems to be (too) large (all entities?). Could you please confirm whether Z11.00 template is required for RLE that are not institutions? Other information: In order to compare with Z02.00 requirements, paragraph 3 (a) specifically required Z 02.00 for RLE that are institutions.

  • 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: 2025_7581
  • Topic: Resolution plans
  • Date of submission:
  • Published as Rejected Q&A: 27/11/2025

The instructions for row 0170 C10.00 seem inconsistent.

The instructions for row 0170 C10.00 seem inconsistent. The title of the line item "Of which: categorised as secured by residential real estate in IRB" refers to secured by residential real estate. Whereas further instructions, "Exposures assigned under IRB approach to the exposure class 'Purchased receivables' pursuant to Article 147(2), point (d)(ii) of Regulation (EU) No 575/2013.", refers to Purchased recaivables. The article mentioned, 147(2)(d)(ii), refers to retail exposures secured by residential property.  Is our understanding correct that this row should not only be populated for Purchased receivables under the IRB approach but actually should be populated for secured by residential real estate under IRB approach?

  • 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_7579
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Presentation of lending for house purchase

Can loans that are directly disbursed to customers be considered as lending for house purchase?

  • 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_7578
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Delimitation of the quantity of liabilities and capital instruments to be computed in the NSFR calculation

In the context of Article 428o(a) CRR, which lists liabilities and capital items subject to a 100% available stable funding (ASF) factor, how should the reference to “before the adjustments required pursuant to Articles 32 to 35, the deductions pursuant to Article 36 and the application of the exemptions and alternatives laid down in Articles 48, 49 and 79” be interpreted? Specifically, should: the Common Equity Tier 1 (CET1) items be included in full, before all adjustments, deductions and exemptions referred to in Articles 32 to 35, 36, 48, 49 and 79; or the CET1 items be taken before adjustments pursuant to Articles 32 to 35, but after the deductions defined in Article 36 and the exemptions and alternatives laid down in Articles 48, 49 and 79?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7577
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 10/11/2025

SPV repack transactions (collateral eligibility)

For recognising received financial collateral when calculating the exposure value under the counterparty credit risk (CCR) framework, does Article 207(2) CRR – which requires that the credit quality of the obligor and the value of the collateral shall not have a material positive correlation – apply?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7576
  • Topic: Market risk
  • Date of submission:

SPV repack transactions

Do SPV repackaging transaction on standardised platforms incur counterparty credit risk (CCR) or is the termination scenario considered a contractual feature that only results in market risk? If these transactions are subject to counterparty credit risk, how should the value of the collateral be taken into account?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7575
  • Topic: Market risk
  • Date of submission:

Calculation of dividend component at individual accounts of the institution

In the context of CRR article 314(2), should the dividend component (DC) at individual level include the dividends received from wholly owned subsidiaries?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7574
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

Validation rules taxonomy V4.0 C_17.01

Validation rule v23510_h incorrect

  • 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_7573
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Calculation rule

Please precise calculation rules for : number of transactions on proprietary accounts (column 0100) number of transactions on clients accounts (column 0110) Cumulated notional amount  (column 0140)

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans
  • ID: 2025_7572
  • Topic: Resolution plans
  • Date of submission:
  • Published as Rejected Q&A: 27/11/2025

Provide a detailed definition of the 'operator' of the FMI.

Please provide a detailed definition of the 'operator' of the FMI, and some examples.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans
  • ID: 2025_7570
  • Topic: Resolution plans
  • Date of submission:
  • Published as Rejected Q&A: 27/11/2025

Finrep validation between F09.01.1 and F18.00 other commitments given

If we have undrawn credit facilities that based on CRR Annex I are reported under Other commitments given in F18.00 r0480 c0010, but they do not meet any of the conditions described in Annex V Part 2.105 (a-c) to be reported in F09.01.1, we cannot report them on F09.01.1 but in F18.00 only.  Validation errors  v2795_m: [F 18.00.e, F 09.01.1] {F 18.00.e, r0480, c0010} = {F 09.01, r0170, c0010} + xsum({F 09.01.1, (r0170, c0010, c0020, c0030, c0035, c0100)}) and v2797_m: [F 18.00.e, F 09.01.1] {F 18.00.e, r0500, c0010} = {F 09.01, r0200, c0010} + xsum({F 09.01.1, (r0200, c0010, c0020, c0030, c0035, c0100)})  require that Other commitments given match in both these tables. What if the conditions mentioned in Annex V Part2.105 are not met for the other commitments given in F18.00?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7569
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 16/10/2025

Definition of ‘demand deposits’ for FINREP reporting

How to report in FINREP loans and advances on demand and short notice that are not readily available at all times?

  • 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_7568
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/12/2025

Disclosure on more periods in one template

In some reports of the Pillar 3 reporting obligations some cells are specifically asking for the amount of the previous periods to be declared : For instance  : Report K6000 - EU OV1 – Overview of total risk exposure amounts : Column 0020 T-1 On those reports we are having some different interpreations with some of our clients regarding what is expected to be fed in column T-1. Some of our client think that column T-1 should always refer to the end of the previous financial year, meaning that when reporting figures for Q2/Q3/Q4 2025 the figures reported in column 0020 should of report K6000 should remain unchanged and should always report the data of Q4/2024.   In our intepretation of the ITS, we understand that in case : The Entity has to report a table on a quarterly frequency in this case the T-1 figures should always reflect the figures of the previous quarter, so for closing date Q2/2025 column 020 of K6000 should be populated with figures coming from Q1 2025, so for closing date Q3/2025 column 020 of K6000 should be populated with figures coming from Q2 2025, so for closing date Q4/2025 column 020 of K6000 should be populated with figures coming from Q3 2025, The Entity has to report a table on a Yearly frequency in this case the T-1 figures should always reflect the figures of the previous year, so for closing date Q4/2025 column 020 of K6000 should be populated with figures coming from Q4 2024 Can you please indicate the correct expectation of EBA ?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 650/2014 - ITS on disclosure by competent authorities
  • ID: 2025_7567
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 26/09/2025

Is the EBA mapping file for Pillar 3 template EU CMS1 correct?

Is the EBA mapping file for Pillar 3 template EU CMS1 correct disallowing amounts to be reported on column a/row 8 and requiring items that could relate to IRB approach to be reported in column b (SA)?

  • 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: 2025_7563
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2025

COREP C22.00 reporting of positions in the reporting currency

Can EBA provide some examples of cases where positions in the reporting currency contribute to the calculation of the capital requirements according to Article 354 CRR?

  • 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_7562
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 12/11/2025

C_ 08.01.a - qx 2068 – “Retail exposures - Secured by residential real estate”

Should the retail exposures secured by residential real estate to a natural person and the retail exposures secured by residential real estate to an SME both be assigned to the exposure class of “Retail exposures secured by residential real estate” in C_08.01.a qx 2068?

  • 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_7561
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Wording error in IFR/IFD regarding the method for calculating capital requirements for counterparty default risk (K-TCD)

Why is collateral posted to the counterparty ignored in the Exposure Value (EV) calculation for a cleared derivatives portfolio under a margin agreement with a negative Mark-to-Market?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7560
  • Topic: K-factor requirements
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

C02 Own Funds Requirements CA2 - Row 0050 - inconsistent requirements for securitisation positions

The ITS for row 0050 states: "CR SA and SEC SA templates at the level of total exposures", information that hasn't changed between DPM 3.2 and DPM 4.0. The validation rule v0205_m with {tC_02.00.a, default: 0, interval: true}: {r0040} = {r0050} + {r0240} + {r0460} + {r0470} is inactive starting with 3/10/2025 and so far the securitisation positions reported on row0470 column 0010 were considered in the calculation of the row0040. Considering the ITS, are the securitisation positions from row 0470 requested on row0050 in regards of each column 0010 TREA and 0020 S-TREA?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7559
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2025

Loans for ADC (Loan for Acquisition, Development and Construction) with underlying exposure residential mortgage

Considering Basel IV (CRR3) was published after the latest NSFR template instructions. Our interpretation is that there are two possibilities: EBA keep the existing wording allowing only exposures secured by mortgages on residential property or EBA amends the wording for NSFR c80 row 0810 and allows any exposures secured by mortgages and loans on residential property.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7557
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 11/12/2025