- Question ID
-
2026_7816
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Interest Rate Risk for Banking Book (IRRBB)
- Article
-
Article 1 – Supervisory shock scenarios
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Not applicable
- Article/Paragraph
-
Commission Implementing Regulation (EU) 2024/855/ instructions in Annex XXIX
- Type of submitter
-
Credit institution
- Subject matter
-
Clarification on reporting of columns 0050–0100 in template J 09.02b (EGDQ_0902b) – delta cashflows vs repricing dates
- Question
-
Could the EBA please confirm the supervisory expectation regarding the correct population of columns 0050–0100 in template J 09.02b? Specifically, should these columns be reported as:(a) delta cashflows / changes relative to the baseline, consistent with the reference to J 01.00 r0040; or (b) repricing dates (in years) of deposits under each of the six SOT scenarios, consistent with the validation rules applied? If repricing dates are intended, we would appreciate clarification on how this aligns with the explicit reference to J 01.00 r0040 and the definition of “Δ EVE” in the ITS.
- Background on the question
-
Based on our reading of the reporting instructions in Annex XXIX, these columns reference the requirement that “institutions shall follow the same instructions as described in {J 01.00; r0040}.” Row r0040 of template J 01.00 is defined as:“Δ EVE under parallel shock up – The change of the EVE under the ‘parallel shock up’ scenario specified in Articles 1(1)(a) and 3 of the EBA RTS on SOT.” On this basis, we interpreted columns 0050–0100 as requiring changes relative to the baseline and populated them with scenario‑specific delta cashflows versus the base case across the six SOT scenarios.
Separately, column 0040 (Baseline scenario – behavioural) was completed in line with the ITS instructions, which specify that the repricing date of deposits should be reported in years. However, the validation warnings received (EGDQ checks), in particular: “Average repricing dates should be less than 30 years,” appear to indicate that columns 0050–0100 are instead expected to contain repricing dates (in years) for the same deposits under each of the six SOT scenarios, rather than delta cashflows. This gives rise to an apparent inconsistency between: the wording of the ITS instructions (via the reference to J 01.00 r0040), and the logic applied by the supervisory validation rules.
- Submission date
- Rejected publishing date
-
- Rationale for rejection
-
This question has been rejected because the issue it raises (i.e. EGDQ) is beyond the remit of the Q&A process and as such it cannot be addressed via a Q&A.
- Status
-
Rejected question