In Annex V, Part 1, paragraph 5(i) of Regulation (EU) No 2021/451, the definition of SMEs is as set out in Commission Recommendation 2003/361/EC of 6 May 2003. By contrast, in CRR 2, the reference to that Commission Recommendation was only included in Article 501 Adjustment of risk-weighted non-defaulted SME exposures but only for the purposes of that article. Consequently, a Q&A was necessary to clarify the use of the same SME definition for FINREP and COREP, which was addressed through EBA Q&A 2013_27. In this Q&A, it is clarified that CRR and COREP should interpret the definition of SMEs in line with Recommendation 2003/361/EC, i.e., the definition of SMEs in FINREP and COREP are aligned.

However, with the approval of CRR 3, which will enter into force on 1 January 2025, a new definition of SMEs is established in Article 5 point 9 of the CRR, which only takes into account the criterion of annual turnover (less than EUR 50 million). This definition will be used for reporting in COREP but not for FINREP, where no change has been introduced.