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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

Disclosure of cash collateral received on derivative transactions in C40 template

Whether the cash collateral received in an account with other institutions should be excluded from disclosure in C40, {0210;0020} 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/11 - Guidelines on disclosure requirements under Part Eight of CRR

Aggregated method for duration of derivatives

Could the EBA please clarify the expected method to aggregate and report the Duration value (column 0020) in template J 02.00 for derivatives?

  • 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

Reporting Requirements on exposures subject to behavioural modelling

What is expected to be reported on the template J08.00b in terms of the perimeter of exposures included in the reporting of relevant parameters? Only those exposures actually subject to behavioural modelling by the institution (thus excluding exposures exposed to Prepayment, NMD behavioural modelling and Early Redemption Risks but non modelled by the institution) or all the exposures exposed to such risks, including those on which models are not applied?

  • 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

Should repricing coupons be included in J06 sheets?

Should repricing coupons be included in J06 sheets in IRRBB reporting? EBA’s validation formula says that repricing coupons should not be included (validation rules v22320_m and v_22321_m). Otherwise the regulation (Final Draft RTS on Standardised Methodologies on IRRBB, Article 1, “’Notional repricing cash flow’ means: (c) Any interest payment on a part of the principal that has not yet been repaid or repriced) says that repricing coupons should be included. And if those repricing coupons are included (as the regulation says) it will cause validation rules v22320_m and v22321_m to be active because repricing notionals are always greater than the notional only.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

FINREP Templates F25 and F13

It has come to our attention that Form F25.01.a contains data elements that overlap with Form F13.3.1. For instance, F25.01.a Row 0120 Column 0030 shares data with F13.3.1a Row 0020 Column 0010. From a business perspective, this inclusion appears incongruous, and we would appreciate an explanation of the rationale behind this decision. Could you please provide the logic and reasoning for including this shared data element between Form F25 and Form F13?

  • 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

Own funds requirement for asset-referenced token issuers

Are issuers of asset-referenced tokens, who are exempt from authorization requirement pursuant to Article 16(2) of MiCAR, subject to the own funds requirement pursuant to Article 35(1) of MiCAR?

  • Legal act: Regulation (EU) No 2023/1114 (MiCAR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Consistency of treatment between the technical guarantees that are subject to the Pillar 2 requirement (Supervisory Expectation of the ECB) and the technical guarantees that are subject to the Pillar 1 requirement (Regulation EU 2019/630).

Should the exemption of technical guarantees from the backstop calculation subject to the Pillar 2 requirement) be extended to the technical guarantees subject to the Pillar 1 requirement?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Collateral Valuation

My question is in respect to the need for independence of valuers. Should a Bank' procedure allow customers to propose valuers subject to acceptance of the Bank and fulfilment of the independence criteria mentioned in the guidelines, would the Bank be considered as fulfilling the need for independence of valuer?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2020/06 - Guidelines on loan origination and monitoring

Scope for dependent financial intermediaries

The dependent financial intermediaries (agents), who acting on behalf of credit institutions, are covered by the DORA Regulation?

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

Powers of MiCAR authority to obtain the information needed to assess recovery and redemption plans and possible mechanism for exchange of information with the prudential authority

In cases where the MiCAR authority differs from the prudential authority under CRD, respectively the competent authority for recovery plans under BRRD, does the Regulation ensure that the MiCAR authority is provided with the powers to gather from the supervised entities (in the course of the ongoing supervision) all information that is necessary in order to duly assess the recovery and redemption plans of banks and investment firms? If there is a risk of insufficiency of information at the disposal of the MiCAR authority, what will be the mechanisms ensuring proper access of information by the MiCAR authority to the information available within the prudential authority on the financial indicators and other key metrics for the purposes of assessment of the recovery and redemption plans, as well as whether Member States are expected to implement special measures to ensure the protection of sensitive information? How the flow of information towards the CRD competent authority from the MICAR supervisors should be assured in order for CRD authority to be able to perform on their tasks? 

  • Legal act: Regulation (EU) No 2023/1114 (MiCAR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Consolidated own funds - minority interests

Preamble Provided that the: in the context of own funds: IFR refers to Title II of Part Two of Regulation (EU) No 575/2013 (CRR) for the application of consolidated own funds in the context of the consolidated fixed overheads requirement article 10 of COMMISSION DELEGATED REGULATION (EU) 2024/1771 states to calculate the consolidated fixed overheads on the basis of the consolidated expenditure figures resulting from the applicable accounting framework on a consolidated basis article 84 of CRR outlines the procedure to compute amount of minority interests of a subsidiary that is included in consolidated Common Equity Tier 1 article 81 of CRR lists the subsidiaries entitled to apply the abovementioned article 84 in the context of the abovementioned investment firms group the list of article 81 of CRR includes just investment firms (art. 81(1)(a)(iv))   Question (part 1) Shall the methodology of article 84 of CRR be applied to all the undertakings included in the consolidated situation (consolidated situation) of the investment firm group, regardless of article 81(1)(a) of CRR? Question (part 2) If so, in the procedure described in article 84(1) CRR shall any unregulated firm (on a stand alone basis – e.g. an ancillary services undertaking, an undertaking pursuing the activities as of point 9 of Annex I of directive Directive 2013/36/EU, …) compute the amount set by article 84(1)(a) as if it were an investment firm?    

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Calculation of the EAD in BA-CVA

To compute the BA-CVA, on netting sets for which an institution computes the EAD using its IMM model, can you confirm that the EAD calculated using current market data should be used?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Grace period for existing contractual arrangements in the register of information

As stated in Regulation (EU) No 2022/2554 (DORA) Article 28, paragraph 3 - As part of their ICT risk management framework, financial entities shall maintain and update at entity level, and at sub-consolidated and consolidated levels, a register of information in relation to all contractual arrangements on the use of ICT services provided by ICT third-party service providers. Is there a grace period for the existing contractual arrangements, or does all the information have to be collected and recorded in the register of information before the regulatory deadline in January 2025? 

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

Metric Amount Weigthted at 50% for Equity AT1 an AT2 between 6 months and 1 Year

When could we have the NSFR Template with EQUITY AT1 and AT2 between 6 months and 1 year weighted at 50% instead 0% today?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

FINREP_3.2.1; F 40.01; Validation Rule EBA_v10676

Template F40.01 contains (among others) column 0110 (Accumulated equity interest [%]) and 0120 (Voting Rights [%]) which are left empty for some rows and therefore trigger a validation error as defined by the EBA. In our reporting empty does NOT mean 0 and therefore using empty fields instead of zero is a more appropriate approach to complete form 40,01. Is this approach correct? What should be reported?

  • 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)

Template F 16.08 validation rule eba_v8193_s

Is it possible to report negative amounts in r 0040 c 0010 (taxes and duties) due to VAT tax refunds from the previous year?

  • 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

Template F 16.08 validation rule eba_v8193_s

Is it possible to report negative amounts in r 0040 c 0010 (taxes and duties) due to VAT tax refunds from the previous year?

  • 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

Reporting of matching liabilities in AE F36.01 template

As the name of columns in AE F36.01 template is “Collateral Type - Classification by Asset type” should matching liability be reported in the same column as assets encumbered against that liability? Or matching liabilities should be reported in columns depending on the nature of the liability itself (so that encumbered asset and matching liability will be reported in different columns of the template)?

  • 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

EBA validation rule v2853

EBA validation rule v2853 requires OTC derivatives in template AE-SOU (F32.04; r0030,c0010) not to be higher than OTC derivatives in FINREP (sum({F 10.00, c0020, (r0300-0320)}) + sum({F 11.01, c0020, (r0510-0530)}) + sum({F 11.02, c0007, (r0240-0260). However in FINREP the net carrying amount should be reported as in the AE-SOU template the gross carrying amount should be reported. The gross carrying amount before accounting netting can be higher than the net carrying amount. Is this validation rule still correct?

  • 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