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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.

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Loans for ADC (Loan for Acquisition, Development and Construction) with underlying exposure residential mortgage

Considering Basel IV (CRR3) was published after the latest NSFR template instructions. Our interpretation is that there are two possibilities: EBA keep the existing wording allowing only exposures secured by mortgages on residential property or EBA amends the wording for NSFR c80 row 0810 and allows any exposures secured by mortgages and loans on residential property.

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

C 66.01 Contractual Maturity Ladder: Eligibility of retained covered bonds issued and received by other members of the same group as counterbalancing capacity

Can a credit institution include in its initial stock of counterbalancing capacity in the C 66.01 contractual maturity ladder central bank-eligible covered bonds that constitute retained own issuances from another member of the same group?

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

Finrep Validation Rules v4975_m and v6058_m6

The validation rules v4975_m and v6058_m appear to systematically fail when institutions hold loans measured at fair value through other comprehensive income (FVOCI). These rules seem not to reflect that fair value remeasurement adjustments on FVOCI loans are recognised directly in the balance sheet through equity. Could the EBA confirm whether these validation rules should exclude FVOCI instruments from their scope, or whether they will be revised to properly reflect valuation adjustments recognised in the balance sheet under IFRS 9?

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

Umgang mit unwiderruflichen Zeichnungszusagen für Fondsanteile im Kreditrisiko Kurzbeschreibung: Zuordnung und Risikogewichtung von Zeichnungszusagen in den Phasen der Fondsauflegung

Im Rahmen der Abbildung unwiderruflicher Zeichnungszusagen für Fondsanteile in unserem Spezialfonds stellen sich uns folgende Fragen:1.    In welcher Forderungsklasse des Kreditrisikos nach 575/2013 der CRR (CIU gem. Art. 132 oder Unternehmen gem. Art. 122) sind unwiderrufliche Zeichnungszusagen während der Phase 3(Auflegung des Sondervermögens) sowie während der Phase 4 (nach Auflegung des Sondervermögens) zuzuordnen?2.    Mit welchem Risikogewicht sind diese Zusagen in den jeweiligen Phasen zu bewerten? 

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)

Corporate exposures in C10.00 memorandum lines r0250 and r0260

In template C10.00, institutions that apply the IRB approach, shall break down IRB exposures by SA exposure class. This template includes the following 2 memorandum lines: r0250 Corporates - F-IRB  r0260 Corporates - A-IRB How should 'Corporates' be interpreted for these two memorandum lines? Does that relate to the volume reported on rows r0100 (Corporates - other) and r0120 (corporates - specialised lending) of template c10.00? The ITS does not clarify this. Therefore the question is whether the sum of rows r0250 and r0260 should reconcile with the sum of C10.00 rows r0100 and r0120? An alternative interpretation is that the SUM of rows r0250 and r0260 should reconcile with the sum of corporate exposures reported in the C08.01 IRB template. We feel that this alternative interpretation is not logical as it would repeat numbers already (separately) reported in C08.01 and separately identifiable, both whether it relates to 'corporates' and whether it relates to A-IRB and F-IRB is identifiable via the Z-axis. Therefore we feel that this interpretation will not add any added value. Could you please clarify to which 'Corporates' lines r0250 and r0260 refer?

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

v6332 - Negative FV changes os hedged intems (C 32.01)

In relation to Q&A 2022_6511 where a question was raised related to validation rule v6566_s. We believe validation rule v6332_m should be deactivated for row 120.

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)

Liability category of margins received

Could you please clarify if margins received, part of a repo or derivative netting agreement can always, regardless of whether the netting results in a net liability or asset position, be considered r0120 - Secured liabilities, or should be allocated to other liability categories as defined in Resolution Plans report Z02? 

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on the provision of information for the purpose of resolution plans

Requirements of Z 11.00 for RLE that are not institutions

Article 3 - Group resolution reporting  We observed some differences, especially for the Z 11.00 template when comparing the 2 parts of the final draft below: the draft proposal to the commission (chapter 3 Draft Implementing Technical Standards, article 3) and the tab in accompanying documents (chapter 2 Background and rationale - 2.2.4 Overview of revised reporting obligations). It seems there is no article requiring specifically from RLEs that are institutions to report Z 11.00 template, although it is included in the tab "Overview of revised reporting obligations". The Z 11.00 template is mentioned in paragraph 7, which seems to either concern the resolution entity or the scope of the article seems to be (too) large (all entities?). Could you please confirm whether Z11.00 template is required for RLE that are not institutions? Other information: In order to compare with Z02.00 requirements, paragraph 3 (a) specifically required Z 02.00 for RLE that are institutions.

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on the provision of information for the purpose of resolution plans

Calculation rule

Please precise calculation rules for : number of transactions on proprietary accounts (column 0100) number of transactions on clients accounts (column 0110) Cumulated notional amount  (column 0140)

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans

Question on the calculation of 'Average amount over the year' related to initial margin on proprietary and client accounts

Are these average of daily, weekly or monthly amounts expected?

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans

Provide a detailed definition of the 'operator' of the FMI.

Please provide a detailed definition of the 'operator' of the FMI, and some examples.

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans

Onboarding capacity - Number of applications from new customers over 1 working day

If the bank has a central team managing all account openings within the group, with colleagues assigned to a specific Member State. E.g. two colleagues are dedicated to opening accounts in Luxembourg, how should we clarify the “Onboarding Capacity”, which is defined as the highest number of applications where the institution has validated the request for a bank service? We seek guidance on which of the following approaches would be most relevant: Real statistics-based calculation: if the average daily number of new accounts opened in Luxembourg is 1 (handled by 2 colleagues in the central team), should the onboarding capacity be reported as 1? And if it takes 15 days to onboard new client (handled by 1 colleague or 2 colleagues in the central team)  in Luxembourg then should we report 0 or 0.1 (1 application /10 days)? Full Central Team Capacity (Single Country): if the entire central team were assigned exclusively to Luxembourg, the average daily onboarding capacity could increase to 5. Should this theoretical highest number of 5 be considered for Luxembourg ? Kindly note that in the capacity of the capacity for every other country would be zero as a consequence. How then to report for the remaining countries? Full Central Team + Project Support (Single Country): If the central team had the additional project support (e.g. temporary resources), the average daily capacity for Luxembourg could reach a higher level, e.g. 50. Should such scenarios be considered for “Onboarding Capacity”?

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans

Instructions to follow regarding new EBA Resolution Reporting

For the sake of clarity, the Bank reports below an example for the “Value of positions on proprietary and client accounts” of the difference between the two instructions 1.      SRB Guidance on FMIR: […] Daily average value at end of settlement day over the previous year. If not available, daily average value over a shorter time period and c0140 and c0150 should be filled. To calculate daily averages, please use the opening days of reported FMIs. If not available, you may use the TARGET2 opening days as a proxy. Total values should be included, not only values of relevant currencies as reported in c0120-c0170 2.      EBA Instructions on New Resolution Reporting – Z09.03: […] Average value at end of settlement day over the previous year.

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Guidance for credit institutions on which countries fall under scope of the Critical Function Report (CFR)

We currently do not see any indication for country-specific information. Will the EBA provide requirements on which countries are to be covered for each Critical Function Report?

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on the provision of information for the purpose of resolution plans

Taxonmy 3.5 - Inconsistant Validation rules

Relating to daisy chain deduction on M 03.00 report, 3 validations rules are inconsistent together (v10839_s, v22357_s and v22545_m)    

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/763 – ITS with regard to the supervisory reporting and public disclosure of MREL

Large Exposures Reporting: Labelling of transactions where there is an exposure to underlying assets

When reporting exposures through transactions where there is an exposure to underlying assets (Article 390(7) of CRR) in the large exposures templates (LE2 and LE3), shall the value “Yes” be reported in column 030 only for the additional exposure stemming from the structure of the transaction, or shall the value “Yes” be reported in column 030 for the exposures stemming from the underlying assets as well?

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

Reporting of Crypto Assets (C36.00 Template) - Risk Type Coverage

With regards to the reporting of information relating to the Crypto Assets (C36.00 Template), we are required to report a) Crypto-asset exposures to tokenised traditional assets; b) Exposures to asset referenced tokens and c) Exposures to other crypto assets. In terms of scope, should this include both Credit and Market Risk positions OR just Credit Risk?

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)

Clarifications about the new column 65 “Offsetting Group” in template C06 under DPM 4.0

Should column 65 (Offsetting Group) in template C06 be reported in 202506?

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

COREP C22.00 reporting of positions in the reporting currency

Can EBA provide some examples of cases where positions in the reporting currency contribute to the calculation of the capital requirements according to Article 354 CRR?

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

Domestic sovereign debt

EBA Q&A 2023_6737 states "Exposures shall be deemed to be domestic where they are exposures to counterparties located in the Member State where the institution is established". Could we confirm that this is also valid in context of the currency of denomination of the debt? e.g. if an EU government issued debt in a currency other than its domestic currency - e.g. Romanian government issues EUR debt instead of RON debt would this still be deemed to be "domestic sovereign debt"?

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

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