Question ID:
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Supervisory reporting - Funding Plans
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions
Reporting Framework 2.9
Disclose name of institution / entity:
Type of submitter:
Credit institution
Subject Matter:
Incorrect validation rules related to Funding Plan

We observed that the following validation rules are causing error in submission to NBB Onegate via dissemination exchange and thus being refused to be accepted in the system.

1) eba_v6230_m

2) eba_v08995_m

3) eba_v08991_m

Background on the question:

1) eba_v6230_m

>v6230_m: [P 01.02 (All rows)] if {c010} != 0 then {c030} != 0 and {c040} != 0 and {c050} != 0<





<subaack:value unit="EUR" decimals="-3" type="float">1490000000</subaack:value>






<subaack:value unit="EUR" decimals="-3" type="float">8135934941.97</subaack:value>

Please note that based on our funding plan, deposits from central bank (TLTRO position) will be fully paid until 2024, therefore 2024 and 2025 position will be zero. Thus, its a valid data point that our report will present zero in row 145 for col 40 and 50.

2) eba_v08995_m

ShortDescription>Total debt securities issued in FP {P01.02,r340,c010} should be equal to the value in FINREP ({F08.01.a,r0360,c0010+c0020+c0030+c0034+c0035}

FormulaExpression: 7969400448.11 = 5378723041.6

Difference = 2590677406.51

The difference is related to Tier 1 and Tier 2 capital that are included as debt securities issued in funding plan but included in FINREP as deposits from credit institutions.

3) eba_v08991_m

ShortDescription>Deposits from credit institutions (excl. repurchase agreements) in FP {P01.02,r130,c010} should be equal to the value in FINREP ({F08.01.a,r0170+r0180+r0190,c0010+c0020+c0030+c0034+c0035}

FormulaExpression: 10056503162.6 = 12647446370.96 

Difference:  -2590943208.36

This difference is related to Tier 1 (r191) and Tier 2 capital (r192) = 2590677406.51 an

Date of submission:
Published as Rejected Q&A
Rationale for rejection:

This question has been rejected because it is considered that EBA guidance or clarification is not needed with regard to the issue that it raises. For example, this can be the case where it is considered that the existing regulatory framework is sufficiently clear and unambiguous, or where different practices may be possible but it is not currently necessary to harmonise these further through the Q&A process.

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Rejected question