The EBA Validation Rule v4786_m  states that EAD (c0105) should systematically be greater than or equal to RWA pre supporting factor (c0110). However, this assumption does not appear to hold in all CRR-compliant situations.  Indeed, under the IRB framework, certain parameter combinations may legitimately result in risk weights exceeding 100%. For example, exposures assessed with a 2.5-year maturity and 40% LGD – parameters commonly observed under Foundation IRB approaches –cumulated with a high PD (10-25%)  - will naturally generate RWAs above the corresponding Exposure Values. In this context, we understand that the underlying rationale of validation rule v4786_m may not be conceptually applicable to all exposure classes and prudential methodologies foreseen under the CRR framework.

Furthermore, previous EBA guidance under Q&A 2017_3394 already acknowledged that situations where RWAs exceed Exposure Values may legitimately arise depending on the methodology applied.

Therefore, we would appreciate clarification on whether the validation rule is still expected to systematically apply under the current prudential framework, including for exposures subject to prudential parameters or methodologies that may generate risk weights above 100%.