Articles 125 and 126 CRR provide for preferential treatment of certain exposures secured by residential or commercial immovable property where, among other conditions, the applicable loss-rate thresholds are met. In relation to immovable property situated in a third country, the CRR provides for the publication of the relevant loss data by the European Banking Authority where the competent authority of the third country does not publish such data and statistically representative information is available.

In its publication Immovable-property loss data, Q4 2025, published under Article 430a(3) CRR, the EBA presents losses and exposure amounts by national immovable property market. In addition to separate rows for European Union and European Economic Area national markets, the publication contains an aggregated row entitled “All national markets outside the Union”. For this row, the EBA reports losses and exposure amounts for residential and commercial immovable property on an aggregate basis. However, the publication does not provide separate amounts or calculated loss rates for Switzerland or for any other individual third-country national immovable property market.

The EBA states that the table by national immovable property market is relevant for assessing the loss-rate thresholds applicable under Articles 125 and 126 CRR. This creates uncertainty as to whether the aggregated row for all markets outside the Union is intended to constitute the relevant EBA publication for each individual third-country market included in that aggregate, or whether the row is provided only as aggregate information and cannot be used to assess the applicable thresholds for a specific national immovable property market.

The distinction is relevant for institutions with exposures secured by immovable property situated in Switzerland. If the aggregated row may be relied upon, institutions could calculate the relevant residential and commercial property loss rates using the losses and exposures reported for “All national markets outside the Union”. If it may not be relied upon, the published data do not enable institutions to determine whether the loss-rate requirements are met for the Swiss national immovable property market.

Clarification is therefore required to ensure consistent application of Articles 125 and 126 CRR and to prevent institutions from applying different interpretations to the same EBA dataset.