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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

Reducing the relevant indicator by using expenditure on the outsourcing of services rendered by third parties which are not subject to rules under, or equivalent to the CRR

May the institution use expenditure on the outsourcing of services to reduce the relevant indicator when calculating own funds requirement under the Basic Indicator Approach (according to Article 316 of the CRR) if the outsourcing services were rendered by third parties which are not subject to rules under, or equivalent to the CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5489
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 23/09/2022

Treatment of direct recoveries under AMA

Can a bank use gross losses net of direct recoveries in modelling for capital purposes under Advanced Measurement Approach for operational risk?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_5040
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Inclusion (or not) of a particular "timing loss" in the C 16.00 and C 17.00 template

Shall a particular "timing loss" in the Operational Risk Losses be included or not in the reporting template for operational risk?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2019_4920
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Provisions as part of the own funds

Can provisions that are made against loss events in the past (i.e. previous accounting periods) be used as a capital substitute to cover future losses? Are these provisions available with a high degree of certainty?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4583
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Operational Risk business line mapping

When an entity carries out an activity for retail customers in a supportive manner to lending and taking deposits from customers in such a way that the entity has neither a separate organisational unit nor a specific internal P/L account for this activity, should it be allocated to the retail banking business line? On the other hand, if the said activity is carried out by the entity in a separate organisational unit with its internal management accounting statements (not necessarily a different legal entity), should its relevant indicator (calculated from the management P/L account) be mapped into the business line established by Article 317 CRR (as an example, in the case of placement of financial products, to retail brokerage)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4433
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Meaning of "the last three twelve-monthly observations" in Articles 315(1) and 317(4) CRR regarding the calculation of operational risk requirements

What is the correct application of the words “the last three”, which can be found in the wording “the last three twelve-monthly observations at the end of the financial year” in Article 315(1) CRR on BIA and in Article 317(4) CRR on STA? In particular, does “the last three” include the current year X when calculating the own funds requirements with reference date 31 December X?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_3969
  • Topic: Operational risk
  • Date of submission:
  • Published as final Q&A: 20/11/2020

Calculation of operational risk capital requirements under BIA

Under the Basic Indicator Approach used to compute own funds requirements for operational risk, how should the interest revenues from impaired loans be considered in the calculation of the Relevant Indicator (RI), namely, applying the effective interest rate on the gross carrying amount of the loans (before allowances/impairment) or on the recoverable amount, after deduction of impairment?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3126
  • Topic: Operational risk
  • Date of submission:
  • Published as final Q&A: 31/07/2020

Operational risk - compliance risk

Does the definition of operational risk include compliance risk?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_1153
  • Topic: Operational risk
  • Date of submission:
  • Published as final Q&A: 25/07/2014

Taking into account insurance effect on operational risk

Recital 52 of Regulation 575/2013/EU (CRR) suggests insurance should be taken into account for the determination of own funds requirements with respect to operational risks, including in simple approaches. How can insurance be taken into account in the basic indicator and standardised approaches of operational risk?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2014_706
  • Topic: Operational risk
  • Date of submission:
  • Published as final Q&A: 14/03/2014

Operational risk

Article 95 (3) in Regulation (EU) No 575/2013 (CRR) has a reference to Title VII, Chapter 3, Section II, Sub-section 1 of Directive 2013/36/EU. From reviewing Directive 2013/36/EU (CRD) there are no sub-sections of the above mentioned Section II. Section II which starts with Article 119 regards Financial holding companies etc. In light of this the reference to the CRD in Article 95 (3) of the CRR does not seem to be correct, could the EBA please provide guidance?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2013_358
  • Topic: Operational risk
  • Date of submission:
  • Published as final Q&A: 08/11/2013