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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.

List of Q&A's

Résolution 1 - how liabilities have to be reported on column 0056 of Z11.00

We want to confirm how liabilities have to be reported on column 0056 of Z11.00 ? It is indicated in "Annex II: Instructions": Type of Liability For liabilities which are reported under Z02.00-c0020-Row as “r0210 - Liabilities towards other entities of the resolution group”, indicate the type of liability as it would have been reported in Z02.00, had the liability not been considered as excluded. We would like to know if operations that are not subject to reclassification in line 0210 of Z02.00 will have to be reported ? Indeed, following the final taxonomy, we note that control e7484 from the validation rules indicates that column C0056 "type of liability" must not be null: In Z 11.00, no empty value in columns (c0020, c0021, c0030, c0040, c0045, c0050, c0053, c0055, c0056, c0060, c0080, c0100, c0110, c0120, c0130, c0150) Furthermore, we note that the list of accepted values for column C0056 is extended to all liabilities in Z02 and not just to liabilities reclassified in line 210.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Introduction of additional mandatory steps or redirections in PISP payment initiation flows

In accordance with Article 32(3) of the RTS on SCA and CSC, may an ASPSP impose mandatory additional steps or redirections (pre-step) in a redirection-based payment initiation flow through a PISP, where such steps or redirections do not form part of the payment initiation process experienced by the PSU when using the ASPSP’s own mobile or online channels?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication

Requirement for ASPSPs to comply with standardized communication protocols under Article 30(3) of Commission Delegated Regulation (EU) 2018/389

Under Article 30(3) of Commission Delegated Regulation (EU) 2018/389, ASPSPs are required to follow communication standards issued by international or European standardisation organisations.In this context, we seek clarification on whether, when an ASPSP has chosen to adopt a recognized communication standard issued by a European or international standardisation body (such as ISO 20022) for its PSD2 interfaces, the standard is expected to be applied consistently and in accordance with its specifications across all such interfaces, regardless of internal documentation or subsequent clarifications issued by the ASPSP, which may reflect internal implementation approaches rather than the standard itself.

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication

Supervisory obligations of NCAs under Article 32(2) of Commission Delegated Regulation (EU) 2018/389

Article 32(2) of Commission Delegated Regulation (EU) 2018/389 states that competent authorities shall monitor the interfaces, the indicators and subject them to stress testing. We are seeking clarification on the interpretation of this provision. In particular, we would appreciate guidance on the EBA’s expectations regarding the scope and nature of NCAs’ monitoring of these interfaces, including the assessment of their operational performance and reliability, as well as the conduct of stress tests, to ensure that the requirements of Article 32(1),that dedicated interfaces shall maintain the same level of availability and performance as the ASPSP’s own online channels, are effectively met.

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication

ITS (Annex II: Instructions), II.20.4, p. 64 II. 20 Z 08.01— Relevant services (SERV 1) II.8.1; General instructions

We would appreciate a confirmation of the following interpretation: In the context of a group level resolution planning reporting, only services associated with core business lines, whose continuity is necessary for the effective execution of the resolution strategy and any consequent restructuring are reported in Z08.01 of the 2026 Resolution Reporting. Is the understanding correct, that essential services of core business lines which are mapped in Z07.03 only to legal entities that are classified as liquidation entities in the PIA Assessment of the Resolution Authority must not be reported by the Union Parent Undertaking or Resolution Entity on a consolidated basis in Z08.01?

  • 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

I couldn´t find this question.

We request EBA’s clarification on the application of Article 402 CRR to exposures fully secured by commercial property classified as IPRE under CRR III, but risk‑weighted as non‑IPRE in accordance with the exemption defined in Article 126(2) because the property meets the national conditions applicable in Sweden (the so‑called “hard test”). Specifically: 2.1 Eligibility for Article 402 when collateral is IPRE by classificationDoes the collateral’s IPRE classification affect eligibility for the Article 402 exposure value reduction, specifically for large exposures where the risk-weighting due to the exemption in Article 126(2) is treated as non-IPRE due to national conditions in Sweden (the so-called “hard test”) 2.2 Treatment under Swedish national conditionsIn cases where national authorities allow commercial IPRE collateral to be risk-weighted as non-IPRE under Article 126(2) (Swedish hard test), can the bank apply the Article 402 reduction, assuming all CRM requirements under Articles 399, 208, and 229 are satisfied? In other words: Does Article 402 eligibility follow the risk-weighting treatment under Article 126.2, or does it follow the classification of the collateral under CRR III?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Résolution 1 - Alimentation des cellules du Z03.01

We want to confirm how to fill the template Z03.01already reported by the entity in FINREP or COREP

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Inconsistency between the report DPM table layout and data point categorization 4.2 and EBA Annex II Instructions.

'- In the DPM 4,2 file in tab Z_07.01.3 a and c, the fields 0100 (Number of transactions) and 0110 (Number of clients) are the components of the Cross Border Activities section. In the Annex II Instructions, the fields 0100 and 0110 are not subject to the Cross Border Activities section but they concern the number of clients and transactions of the total economic function. - In the DPM 4,2 file in tab Z_07.01.4, the fields 0090 (Number of counterparties) and 0100 (Number of transactions) are the components of the Cross Border Values section. In the Annex II Instructions, the fields 0100 and 0110 are not subject to the Cross Border Values section but they concern the total numbers of the total economic function.  Could you please confirm that the breakdowns in the tabs: Z_07.01.3a for the column 0100, Z_07.01.3c for the column 0110, Z_07.01.4  for the columns 0090 and 0100 are not included in the Cross Border section? 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Clarification on the application of Article 215.2(b) of the CRR

Can guarantees issued by a central government for residential mortgages, that covers losses resulting from the non-payment of interest and other types of payments which the borrower is obliged to make, be used for unfunded credit protection if the final guarantee value is determined based on the residual value between an executive sale of underlying residential mortgage collateral and a max guaranteed amount?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

reverse solicitation

The reverse solicitation is where a client or counterparty approaches an undertaking established in a third country at its own exclusive initiative for the provision of banking services, including their continuation, or banking services closely related to those originally solicited.  Is the invitation letter from the agent bank who arranges for the syndicated loans or Schuldscheindarlehen ("SSD") a sufficient supporting document to evidence that a client approaches us at its own exclusive initiative? Or an independent declaration directly made from the borrower (the client) is required?  

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Counterparty treatment of Debt Management Offices (DMOs)

How should Debt Management Offices (DMO) be treated in liquidity reporting for counterparty classification purposes?

  • 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

Applying the provisions of Article 390 (7) CRR and Delegated Regulation 1187/2014 for determining the overall exposure to a client or a group of connected clients in respect of transactions with underlying assets for received collaterals (indirect exposures) after applying substitution approach according to Article 403 CRR 

Does a credit institution have to apply the provisions of Article 390 (7) CRR in combination with Delegated Regulation 1187/2014 to a securitization or investment fund exposure, when the credit institution received the securitization or investment fund exposure as a collateral in an SFT?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1187/2014 - RTS for determining the overall exposure to a client or a group of connected clients in respect of transactions with underlying assets

FINREP Identical Cells 5458783, 5458788, 5459395, 5460187

Could the EBA confirm whether these identical cell checks are correct? If not, should they be updated to align with the previous logic (v8610_i, v8611_i, v10006_i, v10007_i) to ensure consistency between templates and definitions?Please clarify the intended scope of collateral reporting in these templates and whether the current rules will be revised.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

FINREP Validation rules v23845_h, v23846_h, v23847_h

Could the EBA clarify the rationale for excluding rows 0015, 0185, and 0365 from the new validation rules for template F 12.01.a?This change creates inconsistencies with cross-template validation rules such as: v6030_m: {tF_12.01.a, r0010, c0100} - {tF_12.01.a, r0015, c0100} = {tF_04.03.1, r0180, c0050} + {tF_04.04.1, r0140, c0050} v6033_m: {tF_12.01.a, r0180, c0100} - {tF_12.01.a, r0185, c0100} = {tF_04.03.1, r0180, c0060} + {tF_04.04.1, r0140, c0060} v6036_m: {tF_12.01.a, r0360, c0100} - {tF_12.01.a, r0365, c0100} = {tF_04.03.1, r0180, c0070} + {tF_04.04.1, r0140, c0070} These rules assume that rows 0010, 0180, and 0360 include “Cash balances at central banks and other demand deposits.” Additionally, the items “of which: collectively measured allowances” and “of which: individually measured allowances” will no longer consider these balances because the related rules (v5054_m, v5055_m, v5056_m) reference rows 0010, 0180, and 0360 only. Could the EBA confirm whether this exclusion is intentional and, if so, provide guidance on how to reconcile these templates and validation rules?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Controls v4968_m, v5024_m, v5372_m, v5373_m and v5376_m

Please note that controls v4968_m, v5024_m, v5372_m, v5373_m and v5376_m should have the condition "eba_qAS:qx2004" instead of "eba_AS:x2" to comply with column 010 of row 010 of report F_00.01

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

C_07.00 : columns 010 to 040 of line 210

I would like to point out that columns 010 to 040 of line 210 of report C_07.00 should have been ungreased in the EBA 4.2 taxonomy to be in accordance with the EBA's answer to question 2025_7348.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

incoherent formulae

Should the v903188_s control formula apply to columns 0010 and 0020?

  • 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

incoherent formulae

Should the v903188_s control apply for establishments that do not supply the C16.04 status?

  • 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

incoherent formulae

Is the v90304_m control formula consistent with the other controls on C16.02 ?

  • 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

Foreign Exchange Vega Risk Factors Definition

Shall the foreign exchange vega risk factors to be applied by institutions to instruments in the CVA portfolio sensitive to foreign exchange volatility be the implied volatilities of foreign exchange rates between the contractual currency pairs (i.e., no triangulation with respect to the institution’s reporting currency is required)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable