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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

ESG P3 - Template 1 - NACE I classification

The formulas linked to the following rule IDs: v12723_m and v12724_m appears to be incorrect.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2025_7648
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Validation rule v89319_m is not correct

Validation rule v89319_m is incorrect for c0110. Percentages cannot be summed up.

  • 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_7657
  • Topic: Supervisory reporting
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Validation rule v89325_m is not correct

Validation rule v89325_m should be deleted as it is not in line with reporting guidance and inconsistent with corresponding P3 data hub validation rules.

  • 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_7658
  • Topic: Supervisory reporting
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Scope of reporting in Z01.01

Please clarify which scope of consolidation should be applied within the reporting template. Please clarify as well how the reconciliation to the respective measures should be performed depending on the first clarification. 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2025_7663
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

ESG P3 - Template 1 - validation rule v89257_m

Is the validation rules v89257_m correctly defined?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2026_7780
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

FINREP Identical Cells 5458783, 5458788, 5459395, 5460187

Could the EBA confirm whether these identical cell checks are correct? If not, should they be updated to align with the previous logic (v8610_i, v8611_i, v10006_i, v10007_i) to ensure consistency between templates and definitions?Please clarify the intended scope of collateral reporting in these templates and whether the current rules will be revised.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7788
  • Topic: Supervisory reporting - Other
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Template F 13.2.1.c VariableID 433471 and 433464

Following the most recent update to the FINREP validation framework under Reporting Framework 4.2., a new data point categorization has been introduced affecting template F 13.2.1.c, specifically Variable IDs 433471 and 433464. We would appreciate confirmation as to whether this data point categorization has been correctly defined and, if so, clarification on the prudential reporting rationale underlying it. Our concern is that the validation may not be conceptually appropriate in all cases, as not all additions of foreclosed assets necessarily qualify as non-current assets held for sale.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)
  • ID: 2026_7904
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Reporting obligations under Article 3 of the CIR

Whether, and to what extent, will the reporting obligations concerning Relevant Legal Entities (RLEs) under Article 3 of the CIR also apply where a recently acquired RLE is expected, with a high degree of certainty, to cease to exist as a legal entity prior to the adoption of the resolution plan as a result of a legal merger. Additionally, how should this acquired entity be treated for the purposes of resolution planning and related reporting obligations during the interim period between its acquisition and its absorption through merger? We wonder if resolution authorities (RAs) may waive the reporting obligations for this acquired entity for the first reporting cycle after acquisition. Against this background, does the framework require or allow a reclassification of the acquired entity (which used to be a Liquidation entity before acquisition with no reporting obligations) as an RLE immediately upon acquisition, implying inclusion in the group’s resolution plan and submission of the applicable reporting templates? Alternatively, may the acquired entity continue to be treated as a liquidation entity until the legal merger is completed, with its status and standalone reporting obligations remaining unchanged during the interim period? Clarification is sought on whether, in the context of M&A transactions, resolution authorities are expected to adjust the entity’s classification upon acquisition, or whether they may maintain the pre-acquisition status until legal integration is finalised.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7918
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Classification of spread components of floating-rate instruments for contractual repricing reports

How should institutions classify the fixed spread component of a floating-rate instrument when reporting IRRBB repricing cash flows? Article 7 of Commission Implementing Regulation (EU) 2024/857 requires institutions to allocate the spread components of floating-rate instruments "up to the final contractual maturity, irrespective of any repricing of the non-amortised principal". However, Annex V, Section 3, states that the distinction between fixed-rate and floating-rate instruments is to be applied at instrument level. Under this definition, an instrument whose interest payments are contractually linked to an external benchmark is classified as a floating-rate instrument. In practice, two alternative interpretations have emerged: Cash-flow level interpretation: the fixed spread component of a floating-rate instrument is treated as a fixed-rate cash flow extending until contractual maturity and therefore reported within the fixed-rate section of the repricing templates. Instrument level interpretation: the spread component remains associated with the floating-rate instrument and is therefore reported within the floating-rate section, even though Article 7(c) requires the spread cash flows to be allocated up to final maturity. Should institutions report the spread components of floating-rate instruments in the fixed-rate section because they are allocated until final contractual maturity under Article 7(c), or should they remain in the floating-rate section because the fixed/floating classification applies at instrument level according to Annex V?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
  • ID: 2026_7940
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Regulation (EU) 2024/886 of the European Parliament : Specify uniform reporting templates - Submit date

Dear Madam, Sir,   Fiducial Banque received the first IP (instant payment) in 2024.  On April 9, 2026, do we need to submit two declarations : the first for the year 2024  and the second for the year 2025 ?   Thanks in advance for your response.   Best regards Marwa Souissi 

  • Legal act: Regulation (EU) 2024/886 (IPR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7627
  • Topic: Instant payments
  • Date of submission:
  • Published as Rejected Q&A: 03/08/2026

Determining MREL for entities of a group for which resolution plan provides that liquidation is credible and feasible

Where liquidation is credible and feasible either for the parent entity or for all of the entities of a group what is the legal basis for determining and reaching a joint decision on MREL?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2016/1075 - DR on the content of recovery and resolution plans, financial support, independent valuers, contractual recognition of write down and conversion powers, notices of suspension and resolution colleges
  • ID: 2022_6587
  • Topic: MREL
  • Date of submission:
  • Published as Rejected Q&A: 03/08/2026

COREP C 08.05 c0050 “average historical annual default rate” / exposure classes

How is the “average historical annual default rate” in the COREP template C 08.05 c0050 to be reported in the forthcoming years for the specific exposure classes?

  • 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_7616
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 03/08/2026

Inclusion of the CIU portfolio (qx2082) in Total AIRB (qx2023) or FIRB (qx2022) portfolios for the purpose of Templates C_08.01 / C_08.02 / C_08.03 / C_08.05 / C_34.07 and COREP-CODIS P3DH module

We kindly ask for clarifications on the expected reporting of the new CIU portfolio (qx2082) introduced with DPM 4.0 and either its inclusion or not in the Total AIRB (qx2023) or Total FIRB (qx2022) portfolios. The treatment to be adopted is then reflected in the feeding of the Pillar3 COREP - CODIS P3DH module, with specific reference to the tables CR6 (K_26.00.a, K_26.00.b), CR7 (K_27.01), CR7-A (K_27.02.a, K_27.02.b), CR9 (K_29.00), CCR4 (K_04.00.a, K_04.00.b).

  • 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_7612
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 03/08/2026

Accommodation and food service activities

Should accommodation and food service activities (NACE I) be considered an activity sector that significantly contributes to climante change?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR
  • ID: 2025_7626
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 06/07/2026

Exemption from deduction of Equity Holdings in an insurance company from CET1

Institution “A” currently applies the exemption provided under Article 471 CRR, whereby it does not deduct from its own funds a qualifying shareholding held in Insurance Undertaking “C” for an amount not exceeding the amount held in CET1 instruments issued by that Insurance Undertaking as of December 31, 2012 . Following the completion of a merger by absorption between Institution “A” and Institution “B” – as a result of which Institution “B”, as surviving entity, becomes the direct holder of the shareholding in Insurance Undertaking “C” by virtue of universal succession – is Institution “B” entitled to continue to apply the exemption under Article 471 CRR, as previously applied by Institution “A” in respect of such shareholding? Upon completion of the merger mentioned in question 1 above, would Institution “B” be entitled to apply the exemption under Article 471 CRR on a consolidated basis in case its direct shareholding in Insurance Undertaking “C” is transferred (as a result of a partial de-merger) to its wholly owned subsidiary Institution “D”, given that the shareholding in Insurance Undertaking “C” would in any event be held within the consolidation perimeter of Institution “B”? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7903
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 06/07/2026

Definition of "main business" under CRR

How are banks to interpret the concept of "main business" in Article 411(1) of Regulation (EU) No 575/2013 (CRR), read in conjunction with Annex I of Directive 2013/36/EU and Article 3(9) of Commission Delegated Regulation (EU) 2015/61? In particular: can an entity be considered to perform Annex I CRD activities as its "main business" within the meaning of Article 411(1) CRR if: there is an absence of any third-party commercial activity i.e. entity does not offer financial services to any external party for commercial consideration nature of the entity’s operations is ancillary to the group and it exists solely as an instrument of the group's non-financial operations with no independent commercial purpose

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement
  • ID: 2026_7921
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 06/07/2026

Clarification of ETV calculation for mortgages securing more than one exposure

Article 124 paragraph 6 Regulation (EU) No 575/2013 (CRR) specifies the calculation of ETV for IPRE exposures. In order to calculate ETV, the gross value of an exposure should be divided by the value of property. Additionally, this article clarifies that: “For the purposes of the first subparagraph, point (a), where an institution has more than one exposure secured by the same immovable property and those exposures are secured by liens on that immovable property that are sequential in ranking order without any lien held by a third party ranking in-between, the exposures shall be treated as a single combined exposure and the gross exposure amounts for the individual exposures shall be summed up to calculate the gross exposure amount for the single combined exposure.” Our question refers to calculation ETV for joint mortgages – so the mortgage which secures more than one exposures and additionally these exposures may have other mortgages assigned. Based on the above, it’s clear that numerator should include the gross value of all exposures secured by this joint mortgage. Nevertheless, it’s unclear which value should be used in the denominator of ETV in the real life example described below.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7922
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 06/07/2026

Risk weights assignment to IPRE exposures secured by many properties

Articles 125 and 126 paragraph 2 Regulation (EU) No 575/2013 (CRR) specify the rules for risk weights assignment to IPRE exposures, respectively secured by residential and commercial properties. However, these regulations don’t clarify how risk weights should be assigned to IPRE exposure when it’s secured by both residential and commercial property – especially when one property is IPRE (income producing property) and the second one is non-IPRE (the residential property, let’s assume that this is the flat of a counterparty). 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7923
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 06/07/2026

Financial Conglomerates: Reporting of exposures by counterparty within the FC.06 template in light of the reference to “connected client groups” according to Article 4(1), point (39), of Regulation (EU) No 575/2013 and the response to Q&A “2025_7381"

We are seeking clarification about a possible mismatch between ITS and DPM 3.5 (ID v22748_u - T1 L 06.00, column c0020) as part of the compilation of the template FC.06 Template - “Risk Concentration - Exposure by counterparties" within the FiCoD supervisory reporting. In particular, Commission Implementing Regulation (EU) 2022/2454 of 14 December 2022 refers to Article 4(1), point (39), of Regulation (EU) No 575/2013 with reference to the concept of “group of connected clients” for the purposes of reporting in the FC.06 template Risk Concentration – Exposure by counterparties.  If applied the alternative approach, this could require representing on separate rows cases where the same external counterparty simultaneously belongs to a group of connected clients whose parent entity is the central government, as well as to another group of connected clients, resulting in the loss of the uniqueness criterion for records based on the current DPM and the responses provided by the EBA in Q&A ID_2025_7381. We therefore ask whether, for the purposes of reporting in the FC.06 template: the reference to Article 4(1), point (39), of Regulation (EU) No 575/2013 should be considered binding and, consequently, whether the FC0040 column “Name of the group (in case of group of counterparties)” should be regarded as a key value for the unique representation of exposures towards external counterparties in case of an affirmative answer, which would imply the repetition of the same exposures towards the same external counterparty across multiple rows of the FC.06 template, what the allocation criterion for the exposures across the rows should be. Additionally, in case of an affirmative answer for the purposes of reporting in the FC.06 template, we ask what the allocation criterion for the exposures for the purpose of reporting in FC.07 is, as the application of this regulatory reference would imply considering the same exposures to the same external counterparty multiple times.

  • Legal act: Directive 2002/87/EC (FiCOD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2454 – ITS on the reporting of intra-group transactions and risk concentration for financial conglomerates
  • ID: 2025_7536
  • Topic: Supervisory Reporting - FiCOD
  • Date of submission:
  • Published as Rejected Q&A: 26/06/2026

Reporting of minority interest on the NSFR

In the Annex XIII of the applicable reporting framework, and regarding the COREP C 81.00, within the NSFR ITS decision tree, Question 2 refers to “Additional Tier 1 capital” (ID 2.1.2), while Question 11 refers to “Minority interests” (ID 2.9.3). Should qualifying minority interests that relate to Additional Tier 1 capital instruments be reported: under the “Additional Tier 1 capital” row (ID 2.1.2), or under the “Minority interests” row (ID 2.9.3)? 

  • 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_7593
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 15/06/2026