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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

Calculation of the EAD in BA-CVA

To compute the BA-CVA, on netting sets for which an institution computes the EAD using its IMM model, can you confirm that the EAD calculated using current market data should be used?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7211
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 06/11/2024

Own funds requirement for asset-referenced token issuers

Are issuers of asset-referenced tokens, who are exempt from authorization requirement pursuant to Article 16(2) of MiCAR, subject to the own funds requirement pursuant to Article 35(1) of MiCAR?

  • Legal act: Regulation (EU) No 2023/1114 (MiCAR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7210
  • Topic: Own Funds (MiCAR)
  • Date of submission:
  • Published as Rejected Q&A: 21/11/2024

Template 7 - Reporting of Gross carrying amount in total assets

In template 7, should the gross carrying amount of total assets match FINREP or the gross carrying amount as defined by Delegated regulation EU 2021/2178, as asked by the ITS ?

  • 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: 2024_7209
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 20/03/2025

C34.10, reporting of rows related to margin information

What is meant to be reported on rows 0070, 0080, 0170 & 0180 of C 34.10: the exposure values of derivatives or the margin information of 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)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_7208
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2025

FINREP reporting of loans secured by mortgage mandates (Belgium)

Should loans secured by mortgage mandates be reported as 'CRE loan' and/or as 'loans collateralized by immovable property' in FINREP table F 18.02?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2024_7207
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 20/12/2024

Signage of Model Risk Fair Value Adjustments reported in C32.02 (v6575_s)

Model Risk FVAs taken due to market or product factors not captured by a valuation model can be either positive (resulting in a P&L loss) or negative (resulting in a P&L gain). Where the adjustment would result in a P&L gain, it should logically be populated with a negative value. However, validation rule v6575_s states that FVAs reported must be greater than or equal to zero. Please confirm if Model Risk FVAs resulting in a P&L gain should be reported with negative signage in column 0190 of the COREP C32.02 template.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/101 - RTS for prudent valuation under Article 105(14) CRR
  • ID: 2024_7206
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2025

Remaining maturity of the transactions for collateralised transactions

As per CRR Article 162(2)(c)& (d)- This states (as per below). Can the term "remaining maturity" in the below paragraphs be defined as Margin Period of Risk for collateralised transactions and Contractual maturity for un-collateralised transactions? (c)  for exposures arising from fully or nearly-fully collateralised derivative instruments listed in Annex II and fully or nearly-fully collateralised margin lending transactions which are subject to a master netting agreement, M shall be the weighted average remaining maturity of the transactions where M shall be at least 10 days; (d)  for repurchase transactions or securities or commodities lending or borrowing transactions which are subject to a master netting agreement, M shall be the weighted average remaining maturity of the transactions where M shall be at least five days. The notional amount of each transaction shall be used for weighting the maturity;

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/11 - Guidelines on disclosure requirements under Part Eight of CRR
  • ID: 2024_7204
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 07/03/2025

GAR template 7, row 25 Households

For GAR template 7, must the row 24 “households” be always strictly equal to the sum of rows 25 +26 + 27?

  • 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: 2024_7202
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 20/03/2025

Are trust services under the scope of DORA, whatever the nature of the services

Financial institutions (EEFFs) subject to the DORA Regulation understand that Trust services, whatever they are, are “ICT services” and therefore their providers (Trust Service Providers / TSPs) are included in the scope of the DORA Regulation. However, these Trust services do not always constitute or are part of an essential or important function for the operation of such entities, but serve for auxiliary or internal functions of the entities.  Let's take the case of an electronic signature certificate used by a representative to sign contracts with suppliers or internal legal documents: is it essential for the continued operation of a bank, and would the suspension of the service significantly affect the authorized activity of the entity?  Another example: could the use of a platform that allows the remote management of electronic notifications sent to EEFFs by public administrations thanks to connectors that allow the entity to be identified with electronic certificates be considered essential for the EEFFs' operations? It is really a tool that facilitates the administrative procedures of the entity and is not part of the services it provides to its customers.    

  • Legal act: Regulation (EU) No 2022/2554 (DORA)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7200
  • Topic: ICT third-party risk management
  • Date of submission:
  • Published as Rejected Q&A: 19/02/2025

Determination of the amount of eligible receivables from trade debtors as well as fees or commissions receivable within 30 days as liquid assets in accordance with Article 43(3) of the IFR

Should the conditions listed in points a), and c) of Article 43(3) of the IFR be applied in the presented order (a), then c)) or to be complied with on a cumulative basis (a)+c))?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7196
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 10/01/2025

Translation risk when calculating total own fund requirements on consolidated basis using the reporting currency of the consolidated institution

How should the overall own funds requirements be calculated in a consolidated situation for institutions or undertakings, for which Art. 325b(4)(b) CRR applies, i.e. if different institutions or undertakings of the group use different currencies other than the reporting currency of the group?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7194
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 15/11/2024

Treatment of feature of tranching for mortgage backed securities

Under the US NPR,  the Fed has indicated that because the credit risk is to the agency and not the pool, the tranching doesn't count for CSR purposes, and thus the proper risk class to calculate is CSR_NS (not CSR_SNC). Banks in the US subject to FRTB have been following this convention as part of the Fed's Hypothetical Portfolio Exercise. Does the EU expect to follow this interpretation as well?

  • 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: 2024_7193
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 08/10/2024

C 02.00 OWN FUNDS REQUIREMENTS CA2 - Row 0585

Hello,   As a bank reporting software company, we would like more information about FRTB.   In the Reporting framework 4.0, for Corep, for the template : C 02.00           OWN FUNDS REQUIREMENTS   CA2 We have a question about the row “0585- 1.3.4 Risk exposure amount for on- and off-balance sheet subject to market risk of entities applying only the Alternative Internal Models Approach (AIMA) or a combination of AIMA and ASA” There is a mention “See MKR AIMA SUM” in the “2.2 Annex II - Part II - Capital adequacy”   But the template “C 95.00     Alternative internal model approach: Summary of own funds requirements            MKR AIMA SUM” is postponed to 2026.   Can we conclude that this row is empty for 2025 ?   Thanks in advance,   Regards

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7192
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 08/10/2024

The asset resulted from the customer´s obligation to reimburse the payment to the bank from the financial guarantee

In which row in the template F 05.01-Breakdown of non-trading loans and advances by product should bank recognize the asset resulted from the customer´s obligation to reimburse the payment to the bank from financial guarantee?

  • 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_7191
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 20/12/2024

Calculation of loss rates for income producing real estate (IPRE) under the standardized approach for credit risk under the CRR III (Regulation (EU) 2024/1619)

What is the correct calculation of loss rates for the purposes of Articles 125 para. 2 subpara. 3 and 126 para. 2 subpara. 3 CRR (as amended by regulation (EU) 2024/1623, ie. CRR III)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7190
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 23/10/2024

Technical requirements to b_02.02.

Regarding the information register: In the file “Draft Data Point Model” for sheet b_02.02, the concatenation of data points b_02.02.0010-0060 needs to be unique for CASPER to accept this. From a business perspective, we cannot agree with this requirement. Furthermore, we cannot see this requirement being derived from the current ITS. Particularly in the case of cloud services, the information may differ for the same entries in x for data storage and processing.

  • Legal act: Directive 2022/2556/EU (DORA)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7188
  • Topic: Other DORA topics
  • Date of submission:
  • Published as Rejected Q&A: 18/02/2025

Standardansatz für das Gegenparteiausfallrisiko

Guten Tag Wir haben nun eine Unklarheit bezüglich dem CELEX 32019R0876, Art 274 Abs 5 a) Der Netting-Satz besteht ausschliesslich aus verkauften Optionen. Frage: Sind die verkauften Optionen aus Banksicht oder aus Kundensicht gemeint d.h. ist der Kunde short die Optionen oder die Bank ? Vielen Dank & freundliche GrüsseDenis Meylan P.S. Das EAD kann auf 0 gesetzt werden, bei einem reinen short Option Portfolio (aus Kundensicht oder Banksicht - darum die Frage).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/62 - DR with regard to the leverage ratio
  • ID: 2024_7187
  • Topic: Leverage ratio
  • Date of submission:
  • Published as Rejected Q&A: 23/10/2024

Can the Article 122a adjustment be combined with the Article 501 SME-adjustment?

The Article 122a paragraph 3  letter c subletter ii CRR says, that if all the criteria are met, there can be a factor of 80 % applied. But it can't be combined with the 75 % adjustment of Artikle 501a. But can it be combined with the adjustment for SMEs due to Article 501?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7186
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 19/03/2025

Scope of public offering

"Question: Regarding ARTs or EMTs under MiCAR, what services provided in or into the EU constitute an offering to the public, a seeking admission to trading or a placing of an ART or EMT?

  • Legal act: Regulation (EU) No 2023/1114 (MiCAR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7185
  • Topic: Scope and definitions (MiCAR)
  • Date of submission:
  • Published as final Q&A: 17/01/2025

C 07 - Clarification on reporting the effect of the FX Mismatch

We seek clarification on some topics in regard to the newly introduced reporting requirements of the FX Mismatch (Art. 123a CRR III) in C07.The changes have been introduced with the final draft of the ITS templates for columns 0215 and 0220 to exclude/include the fx mismatch effect. 1. Our assumption is that the validation rules asking for consistency between column 0200, 0215 and the riskweight of the row in which the exposure is reported will still exist in the future. (e.g. v0324_m etc)Can you therefore confirm that the expectation for exposures affected by the fx mismatch is that they are to be reported in the row for the "unadjusted" riskweight instead of the riskweight including the effect of the fx mismatch? 2. as no specific column for the effect of the mismatch was introduced, can you confirm that validation rule v0329_m will become obsolete?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2024_7182
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2025