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Q&As refer to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.

Please note that the Q&As related to the supervisory benchmarking exercises have been moved to the dedicated handbook page. You can submit Q&As on this topic here.

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List of Q&A's

Identification of the part of the exposure not covered by the lien on the property

To identify the part of a non-ADC-exposure that shall be treated as stated in Article 124(1), which amount of the exposure has to be compared to the nominal amount of the lien?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7311
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/10/2025

Mixing approaches (loan-splitting, ETV) for real estate exposures collateralised by multiple immovable properties

Is it allowed to split an exposure/loan into using different riskweighting methods (loan-splitting vs ETV) in case they are collateralised by multiple immovable properties with different characteristics?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7296
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/10/2025

Calculating ETV in case of a broken sequence of mortgages

Is it allowed to distribute the property value (V) of the ETV formula in case the sequence of mortgages is broken to achieve optimal results for the individual ETV-ratios?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7294
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/10/2025

CRR3 - ETV calculation

With the CRR3 application, can you please confirm us the way to calculate the ETV ratio?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7175
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/10/2025

Treatment of Subscription Agreements in CIUs as Off-Balance Sheet Item

Clarification is sought on the prudential treatment of subscription agreements entered into for the acquisition of units in Collective Investment Undertakings (CIUs), specifically in the context of off-balance sheet exposures under Article 111(4) of the Capital Requirements Regulation (CRR). More specifically, clarification is sought on the treatment of subscription agreements upon signing of the relevant documentation but which effects, at the time of signing, is subject to the verification of conditions precedent (these conditions normally being out of the control of the subscriber) such as the relevant fund reaching a certain size.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7508
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/10/2025

Computation of the operational risk valuation adjustment after entry into force of Regulation - EU - 2024/1623

To comply with article 105, point (10) of CRR, and with article 17 of the Delegated Regulation  2016/101 we ask the following two questions:  Does the calculation of own funds requirements for operational risk in accordance with Title III of Part Three of CRR include operational risk relating to valuation processes? If the answer to the question above is yes, does the Delegated Regulation 2016/101 allow to avoid double counting of operational risk relating to valuation processes?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/101 - RTS for prudent valuation under Article 105(14) CRR
  • ID: 2025_7506
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 30/10/2025

Validation rules taxonomy V4.0 C06.02, v23688_s

The EBA Validation rules taxonomy v23688_s seems not relevant.  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions
  • ID: 2025_7543
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2025

C02 Own Funds Requirements CA2 - Row 0050 - inconsistent requirements for securitisation positions

The ITS for row 0050 states: "CR SA and SEC SA templates at the level of total exposures", information that hasn't changed between DPM 3.2 and DPM 4.0. The validation rule v0205_m with {tC_02.00.a, default: 0, interval: true}: {r0040} = {r0050} + {r0240} + {r0460} + {r0470} is inactive starting with 3/10/2025 and so far the securitisation positions reported on row0470 column 0010 were considered in the calculation of the row0040. Considering the ITS, are the securitisation positions from row 0470 requested on row0050 in regards of each column 0010 TREA and 0020 S-TREA?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7559
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2025

CoRep Reporting C07.00 Template - Clarification regarding Default in Equity Exposures

The COREP template C07.00 requires institutions to report all counterparties treated under the Standardised risk weight approach to be split by Asset Class. These 'Asset Classes' are defined under Article 112 of CRR. The template clearly calls out that for the 'Exposure in Default' Asset Class, any exposure that is not subject to 'Equities' (under Article 133) should be included, hence the Equities exposures positions are not reported under Exposure in Default Asset Class.  The COREP template has a specific section to report Default in Equity Exposures – Row 0015. However, there is no definition of Equity Exposures at Default from a standardized risk weight perspective, hence we are seeking clarity on how this should be managed/disclosed. For example, we are now needing to disclose counterparties that have had loan restructuring and as part of this, equities have been issued and hence, this is where the Equity exposure position is classified as default.   

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions
  • ID: 2025_7534
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

CoRep Template C07.00 - Clarification on “of which: Exposures to central banks”

As part of COREP template C07.00, Banks are required to disclose counterparties subject to Standardised risk weight split by Asset Classes such as 'Central Government or Central Banks', 'Regional Government', 'Public Sector Entities'. The template also requires additional data points to be disclosed including “of which: Exposures to central banks” – Row no. 0011. The COREP guidance for the above Row 0011 refers Article 112 (a) of CRR. However this article refers to Asset Class as “Exposures to Central Government or Central Banks”. This leads to an ambiguity in the disclosure. The firm is currently disclosing only exposures to 'Central Banks' even though the article reference is to Exposure to Central Government or Central Banks. We seeking to confirm the treatment to be applied. 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions
  • ID: 2025_7535
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Reporting of losses from lending collateralised by immovable property (C_15.00)

For loans secured by real estate property with any of the credit history scenarios below, should losses, and in case of scenario iii., exposures, be reported in COREP template C 15.00?  If yes, for which default event or events should the estimated losses be included in the reporting (i.e. is it correct to assume that under scenario ii. only losses estimated for the last default event in the reporting period should be included)?  Also, which default event should be used as a reference date for the reported exposures under scenario i. (the reporting period or the year prior to it) and under scenario ii. (exposure value at the first or at the last default event during the reporting period)? i. scenario:  The loan secured by real estate property had defaulted in a year prior to the reporting period, subsequently it exited/cured from the default state in the reporting period, but later it defaulted again during the same reporting period, and it stayed in the default state until the end of the period. ii. scenario:  The loan secured by real estate property had defaulted in the reporting period, later it exited/cured from the default state in the same reporting period, but still in the same period it defaulted again and stayed in the default state until the end of the period. iii. scenario: The loan secured by real estate property had defaulted in the reporting period and subsequently in the same period the institution stopped recognising the real estate property as CRR-eligible collateral (the real estate property ceased to meet the eligibility criteria).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions
  • ID: 2025_7540
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Validation rule v23688_s requiring only non-negative amounts appears incorrect

Is validation rule v23688_s incorrect? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2025_7547
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

C06.02 - v23688_s - Non negative control

The control indicates that the following columns have to be positive :   c0360 = consolidated own funds   c0370 = of which : common equity Tier 1   c0390 = oh which: contribution to consolidated result Should this control be applicable?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7548
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

C07.00 - v23338_m - RW of 70% empty

The EBA Validation Rule v23338_m applicable to C07.00 COREP template states that the line 210 that concerns the RW of 70% must be empty. Should this control should be applicable?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7549
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

C17.01 - v23507_h - Sum of number events by Basel Business Line

Is the aggregation logic assumed by the control v23507_h is not applicable in this context.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7550
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

C17.01 - v23508_h - Sum of number of events by Basel Business Line

Is the aggregation logic assumed by the control v23508_h applicable in this context?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7551
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

v23509_h and v23510_h

Are the validation rules v23509_h and v23510_h correct when reading the reporting instruction of the ITS. In our view the reporting instruction of the ITS is not clear enough.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions
  • ID: 2025_7552
  • Topic: Supervisory reporting
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Validation rules v23509_h and v23510_h appear incorrect

Are validation rules v23509_h and v23510_h correct?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2025_7555
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

C_ 08.01.a - qx 2068 – “Retail exposures - Secured by residential real estate”

Should the retail exposures secured by residential real estate to a natural person and the retail exposures secured by residential real estate to an SME both be assigned to the exposure class of “Retail exposures secured by residential real estate” in C_08.01.a qx 2068?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions
  • ID: 2025_7561
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025