'Cash balances at central banks' and 'other demand deposits' should be included in disclosure template EU CQ4. This is not in contrast with Article 442(c) and (e) of the Regulation (EU) No 575/2013 (CRR). Article 442 of the CRR sets out disclosure requirements for “exposures to credit risk and dilution risk”, thereby defining a broad scope. References to “loans, debt securities and off-balance sheet exposures” in points (c) and (e) specify core disclosure categories, rather than an exhaustive list. Neither Article 442 of the CRR, nor any other CRR provision explicitly excludes “cash balances at central banks” or “other demand deposits”, which economically represent claims on counterparties and may constitute credit exposures. The ITS, including EU CQ4, provide a standardised presentation framework that results from applying the scope of the definition of non-performing  exposures in accordance with the Article 47a CRR. 

Take into consideration that the IT solutions (Annex V) to Commission implementing regulation (EU) 2024/3117 (Part 1, paragraph 32 and Part 2, paragraphs 2 and 3) specify that ‘cash balances at central banks’ and ‘other demand deposits’ are ‘loans and advances’, but they shall be reported outside the accounting portfolios of financial assets, in previous version of the Finrep template F 20.04 (until version 2.9), 'cash balances at central banks' and 'other demand deposits' were included in the row 140 ‘Loans and advances’. Since version 3.0., a separate row 0075 has been created for this item in line with the reporting in other templates (e.g. F 18.00).

Accordingly, the inclusion of FINREP row 0075 in the mapping of EU CQ4 should be applied.