Question ID
2025_7563
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Transparency and Pillar 3
Article
434a
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR
Article/Paragraph
2024/3172 (ITS)
Type of submitter
Credit institution
Subject matter
Is the EBA mapping file for Pillar 3 template EU CMS1 correct?
Question

Is the EBA mapping file for Pillar 3 template EU CMS1 correct disallowing amounts to be reported on column a/row 8 and requiring items that could relate to IRB approach to be reported in column b (SA)?

Background on the question

The EBA Pillar 3 mapping tool (as published on 22 May 2025) file contains the following mappings for the template EU CMS1: 

 

Row 7 / column b = row 8 - sum of rows 1 to 6

Row 8 /column b = {OV1, row 29, column a} - {CMS1, row 8, column a}

 

The OV1 template captures the r0690/c0010 of the C02 template (OTHER RISK EXPOSURE AMOUNTS). 

 

The combination of these rules results in the amount reported in row r0690/c0010 of template C02 being mandatorily reported in column b of the template CMS1, i.e. forcing disclosure under the standardised approach of all items under ‘OTHER RISK EXPOSURE AMOUNTS’ related to credit risk.

 

This appears incorrect as items of rows 0750 ( Of which: Additional stricter prudential requirements based on Article 459 of Regulation (EU) No 575/2013) and row 0760 (Of which: Additional risk exposure amount due to Article 3 of Regulation (EU) No 575/2013) can be related to IRB approaches as well and should be disclosed in column a of the template CMS1. 

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because the issue it raises is beyond the remit of the Q&A process and as such it cannot be addressed via a Q&A. The matter it refers to will however be considered for a forthcoming version of the mapping tool.

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Status
Rejected question