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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.

List of Q&A's

Level of EVE, NII and MV under Baseline scenarios reported positive for individual currencies (material or immaterial) in J1 report

Why is expected to always have the Level of EVE, NII and MV under Baseline scenarios reported positive for individual currencies (material or immaterial) in J1 report? Currently for the the rows of J1 report which reffer to Level of EVE, NII and MV under Baseline scenarios there is a validation rule (v16332_s) which throws a warning if the amount is negative regardless if the report is aggregated or for individual currencies. We believe this rule should be applied only for aggregated currencies and not for individual currencies as there could be a situation where the bank has a liability exposure in a specific currency which will end as a negative level of EVE/ NII or MV but when the aggregated report is obtained the final values are positive. Also, if the current rule is maintained, the results from J3 report will not be consistent with the ones from J1 as the negative amounts have to be reported positive. 

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)

Treatment of two-legs derivatives and validation Rule EBA V16337 (Tab J0200)

Could you please clarify the sign of the carrying amount for derivatives in J0200 ?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)

v16319_s and v16322_s (IRRBB) – non-negative rule not applicable to derivative rows

In line with the de-activation of v22331_s, we request to de-activate v16319_s and v16322_s as well

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

DPM 4.0 taxonomy, several validation rules are not correct

During the analysis of DPM 4.0 taxonomy, we identified the following issues in the validation rules: EBA validation rule, v23083_m (C25.01) Current rule: with {tC_25.01.a, (c0010, c0020, c0050, c0060, c0070, c0090, c0100, c0110, c0140, c0150, c0160, c0170, c0180, c0200, c0210, c0220, c0230, c0240, c0250, c0270, c0280, c0290), default: 0, interval: true}: {r0040} = {r0050} + {r0060} + {r0090} + {r0100} + {r0110} Proposal: the rule should be deactivated Reason: CVA-risk amounts can be non-additive due to portfolio effects   EBA validation rule, v23345_s  (C25.01) Current rule: with {tC_25.01.a, default:null, interval:false}: {(r0010, r0020, r0030, r0040, r0050, r0060, r0070, r0080, r0090, r0100, r0110, r0130), (c0010, c0020, c0060, c0100, c0110, c0140, c0150, c0160, c0170, c0180, c0200, c0210, c0220, c0230, c0240, c0250, c0270, c0280, c0290)} >= 0 Our Proposal: the rule should be deactivated Reason: Marginal CVA-risk amounts can be negative due to portfolio effects   EBA validation rule, v23710_s  (C25.01) Current rule: with {tC_25.01.a, default: null, interval: false}: {(r0010, r0020, r0030, r0040, r0050, r0060, r0070, r0080, r0090, r0100, r0110, r0130, r0230, r0240), (c0070, c0090)} >= 0 Our Proposal: the rule should be deactivated Reason: Marginal CVA-risk amounts can be negative due to portfolio effects   Mapping Pillar 3 disclosures templates with supervisory reporting (Template EU CMS2. Column d) Column d (RWEAs calculated using full standardised approach) shows the relevant Output-Floor S-TREA without Floor transitional rules according to CRR Article  465 (3) – (13). It is calculated as a surcharge of the current Output Floor S-TREA. But the values from Template C10.00  for transitional rules regarding  EXPOSURES SECURED BY MORTGAGES ON RESIDENTIAL PROPERTY are missing and must be included analogous to template EU CMS1 (à there: {C10.00, r0010, c0090} + {C10.00, r0010, c0100}).    EBA Validation rule v1659_m (C07.00) Current rule: {c0200} = {c0150} - {c0160} - ( 0.90 * {c0165}) - ( 0.8 * {c0170}) - ( 0.6 * {c0175}) - ( 0.5 * {c0180} - {c0195}) Proposal: {c0200} = {c0150} - {c0160} - ( 0.90 * {c0165}) - ( 0.8 * {c0170}) - ( 0.6 * {c0175}) - ( 0.5 * {c0180}) - {c0195} Reason: the term  {c0195} should be excluded from the 0.5-weight-bracket, because UCCs have under the transitional arrangement a 0% CCF and must be subtracted completely.   EBA Validation rule v6052_m (C 09.02) Current rule: {r0150} = {r0010} + {r0011} + {r0012} + {r0013} +{r0020} + {r0030} + {r0060} + {r0132} +{r0140} Proposal: {r0150} = {r0010} + {r0012} + {r0013} +{r0020} + {r0030} + {r0060} + {r0132} +{r0140} Reason: the "of which" position should not be part of the sum. 

  • 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)

Transfer of banking business – presentation of transaction in FINREP movements tables

An application for approval of the legal merger of Bank A with Bank B has been submitted to the Central Bank of Cyprus. The legal merger will be completed in two steps, (i) the transfer of banking business of Bank B to Bank A via a transfer of business agreement, (ii) the merger of the two entities via a scheme of reorganisation. Following step (i) of the merger, Bank B will not maintain any activities or deposits and it will surrender its banking license. As such it will cease to be a credit institution and will temporarily obtain ~36% of Bank A through the transfer of business to Bank A (subject to regulatory approvals). The said legal merger is expected to be effective from 1 July 2025 onwards. The first FINREP report that will be prepared for the “merged” entity will be for reference date 30/09/2025. Given the transaction described above, how should we approach the FINREP tables that show movements (i.e. tables F12.01, F12.02, F18.01, F24.01, F24.02, F25.01& F 25.03)? In our view, the possible options are as follows: (i) Opening balances comprise of the sum of the opening balances of both entities (prior to the transaction) as at 01/01/2025. Additions/disposals/other movements during the reference period are again the sum of the additions/disposals/other movements of the two entities. As such the transfer of balances from Bank B to Bank A will not be explicitly shown. (ii) Amounts transferred from Bank B to Bank A form part of the inflows/additions of the “merged” entity, meaning the opening balances on the movements tables present the figures as presented by Bank A in its current reporting.  (iii) Opening balances will be shown as nil and all will be shown as “Inflows”, as if a new entity is set up.

  • 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

Validation Rule EBA_v22095 (tab J0200) : Duration

Could you please deactivate the validation rule EBA_v22095 for IRRBB reporting ? This validation rule checks that the sum of the modified durations for the sub-categories Retail, Wholesale Non-Financial, Wholesale Financial equals the modified duration of the Loans and Advances category. However, modified duration is not an additive measure.

  • 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)

Instructions for completing the register of information-Functions identification-Licenced activity

In the specifications of the DORA Register of Information file, in sheet B0601 for insurance and reinsurance undertakings, the list of values "List of possible values for all data fields with drop-downs (updated 3 March 2025)" appears, which does not include classes 17 ("Legal Expenses Insurance") and 18 ("Assistance"). Please inform us how these activities should be declared in the column "Licensed activity B06_01_0020".

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information

Exist a definition of information security standards

In DORA Article 28 (5), reference is made to "appropriate information security standards" and "of the most up-to-date and highest quality information security standards". Is There a definition of which standards are applicable here, or can credit institutions define the desired requirements themselves?"

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Definition of financial counterpart

Can you confirm whether our interpretation of the notion of ‘financial counterpart’ is correct?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Validation rule v8821_m

The validation rule defines that in the event that column 020 of the template is valorised with the identification code indicating LEI code (eba_qCO:qx2000) then column 030 must be valorised with a LEI code.In reality, column 020 indicates the type of code to identify the third-party ICT service provider indicated in column 010. Consequently, shouldn't the validation rule be correct that the check should be made on column 010 and not 030?  

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Validation rules taxonomy V4.0 C_10.00

The formulae of the control v23052_m seems incoherent

  • 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

Validation rules taxonomy V4.0 C_08.01.a,C_08.02,C_09.02

The EBA Validation rules taxonomy v7551_m 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

Validation rules taxonomy V4.0 C_08.01.a,C_08.02,C_09.02

The EBA Validation rules taxonomy v7549_m 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

Validation rules taxonomy V4.0 C08.01/C08.02

The EBA Validation rules taxonomy v10667_m 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

Validation rules taxonomy V4.0 C08.01/C08.02

The EBA Validation rules taxonomy v10666_m 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

Validation rules taxonomy V4.0 C08.01/C08.02

The EBA Validation rules taxonomy v10664_h 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

Disclosures of Number of Staff Management body in its supervisory function in FINREP Template 44.4

For the management body in its supervisory function and senior management in Template 44.4 column 0040, and management body in its management function in column 0030, should only the number of members of the management body and senior management in EU parent company be reported, or should the number of members of the consolidated subsidiaries also be included? Same question applies to the variable and fixed remuneration rows 0010 and 0020, and other staff expenses row 0030.

  • 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)

FINREP – Template 40 Group structure (40.1 “entity-by entity” – 40.2 “instrument-by-instrument”) – Notion of Group scope

Could you clarify if the associated companies whose holder is a group company that consolidates within the prudential scope by equity method should be included individually?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

Identical Cell Template C 10.00

Can you confirm that the definition of these cells as identical cells is correct?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Validation rules taxonomy V4.0 C_10.00

The formulae of the control v23053_m seems irrelevant

  • 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