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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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List of Q&A's

Net liquidity outflows over a 30 calendar day stress period

If a facility agreement includes a condition that causes a committed revolving facility to become non‑revolving during a period of stress for the credit institution, should the net liquidity outflow for LCR purposes then be calculated based on the maturity date of each individual drawing rather than the overall facility maturity date?

  • 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_7719
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 31/03/2026

Incorporation of historical data from integrated entities when historical information is not representative of current underwriting standards

Should an institution incorporate historical default data from acquired or merged entities into its IRB model estimates for PD, LGD, and CCF when calculating RWA for the acquiring institution’s exposures originated before and after the merger? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/16 - Guidelines on PD estimation, LGD estimation and the treatment of defaulted exposures
  • ID: 2026_7701
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 31/03/2026

Counterparty treatment of Debt Management Offices (DMOs)

How should Debt Management Offices (DMO) be treated in liquidity reporting for counterparty classification purposes?

  • 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_7662
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 31/03/2026

Liquid assets - CIUs

For the purposes of Article 43 (1) (b) of the IFR should CIUs that hold short-term unencumbered deposits at a credit institution or financial instruments referred to in article 43 (1) (c) of the IFR be considered to fulfil the condition set out in Article 15 (1) (b) of Delegated Regulation (EU) 2015/61?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7622
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 31/03/2026

Treatment of Payment Institution and Electronic Money Institution safeguarding accounts in LCR C73.00 reporting

How should the safeguarding accounts of Payment Institutions (PIs) and Electronic Money Institutions (EMIs) be treated in the LCR C73.00 template? According to the legal requirements (e.g. PSD2 and EMD2), PI/EMI funds must be segregated from own funds and held separately in safeguarding accounts with credit institutions or invested in secure assets. It is unclear whether such safeguarded funds should be considered as deposits of financial institutions and therefore reported in row 230 of LCR C73.00, or whether they may be treated as other customer deposits and reported in row 240.

  • 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: 2025_7564
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 31/03/2026

Application of the ‘sole purpose test’ with respect to the criterion predominant source of revenues.

Art. 2 (7) (a) of Commission Delegated Regulation 2023/2175 stipulates the following Revenue Test: “the entity has a strategy and the capacity to meet payment obligations consistent with a broader business model that involves material support from capital, assets, fees or other sources of income, by virtue of which the entity does not rely on the exposures to be securitised, on any interests retained or proposed to be retained in accordance with Article 6 of Regulation (EU) 2017/2402, or on any corresponding income from such exposures and interests, as its sole or predominant source of revenue”. The ESA report (JC 2025 14) from March 2025 in particular in the context of Collateralised Loan Obligation (CLO) securitisations as they relate to third party origination CLO vehicles, reiterates this guidance and clarifies that the word “predominant” translates into a 50% threshold: “[…] According to the RTS, this means that the entity’s revenues should correspond to no more than 50% on the exposures to be securitised, risk retained assets or proposed to be retained in accordance with Article 6 of the SECR, or any corresponding income from such exposures and risk retained assets. […]”.  It is also acknowledged that the JC of the ESAs seek to invite the European Commission to confirm this interpretation and if needed to consider some legislative adjustments to clarify the term “sole purpose” in the Level 1 text. The Submitter would like to confirm that in situations where such aforementioned originator invests in securitization tranches in excess of the minimum risk retention in accordance with Art. 6 of the Securitisation Regulation, the Revenue Test is met if: X / Y ≤ 0.5  where X means the sum of gross revenues based on exposures to be securitized and gross revenues of tranches mandatorily held to fulfil the minimum risk retention, and  Y means all gross revenues. The gross revenues of tranches voluntarily held in excess of the minimum risk retention should therefore only be included in Y.

  • Legal act: Regulation (EU) No 2017/2402 (SecReg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2023/2175 - RTS on the risk retention requirements for originators, sponsors, original lenders, and servicers
  • ID: 2025_7594
  • Topic: Provisions applicable to all securitisations
  • Date of submission:
  • Published as Rejected Q&A: 31/03/2026

Discrepancies between taxonomy packages

The Partial Taxonomy Packages published and still available from contain potentially outdated information and most likely it cannot be used as is. The current major concerns are the differences found between the 3.2 Partial Taxonomy Packages and the 3.2 Full Taxonomy Package. Here we have identified differences that in the DataPoint Ids. (meaning that certain cells must be delivered differently into XBRL-CSV) It seems that there are further differences in the latest 4.1 EBA Full Taxonomy Package compared to the 3.2 Full Taxonomy Package, however these differences should not modify the output. (meaning no difference in the instance generated)

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7527
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as Rejected Q&A: 17/03/2026

EBA mapping file for Pillar 3 template EU CMS2

The mapping file for EU CMS2 template seems to contain multiple issues: 1) The Naming of the row EU 7a does not conform to the regulation 2024/3172 (ITS). In the ITS, the row is not an ‘of which’ row, but an independent row. 2) The row 6.2 (Of which: Retail - Secured by residential real estate) appears to be redundant. Following the ITS instructions for this section, “Where the IRB exposures would have been allocated in a different exposure class in the standardised approach (SA), the IRB exposures shall be excluded from their IRB exposure classes and they shall be disclosed   in one of the following exposure classes of the Standardised approach”. All exposures (partially) secured by real estate must be disclosed on row EU 7a or EU 7c , no exposure can be disclosed on row 6.2, which is an ‘of which’ category of row 6 (Retail). The mapping to COREP C10 row 0170 appears incorrect as it conflicts with the ITS instruction to reclass the exposures.  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7698
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 17/03/2026

Clarification on the term “fully and completely secured by mortgages” in Article 47c(1) in the context of Non-Performing Exposures (NPEs).

Within the context of Article 47c(1), how should the “secured” part of a non-performing exposure be interpreted, given that the term “fully and completely secured by mortgages” is no longer defined in Title II of Part Three?

  • 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_7583
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 16/03/2026

Z 09.01 – FMI Services – providers and users (RESOL2)

We ask confirmation that the column “0140-Resolution resilient contract” applies only in the case of indirect access to FMIs and that for FMIs with direct access, the value “Yes” should be reported

  • 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_7705
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 13/03/2026

Resolution Reporting on FMI

With reference to Resolution Reporting on FMI Services, we would like to bring to your attention some questions regarding the scope and data reported, particularly in cases where the Bank participates indirectly in certain FMIs. With reference to item "Z 09.03 - Financial Market Infrastructure Services (FMI) - Key Metrics (FMI 3)", we would therefore like to know whether, for FMIs to which we participate indirectly, it is possible to report intermediary data instead of individual FMI data, and, if so, how to complete the individual items. The question specifically concerns the following reporting fields: • Z 09.03/60-70 Value of positions on proprietary and client accounts • Z 09.03/80 Number of clients covered by omnibus accounts • Z 09.03/90 Number of clients covered by segregated accounts • Z 09.03/100-110 Number of transactions on proprietary and client accounts • Z 09.03/120-130 Value of transactions on proprietary and client accounts This requirement arises from the fact that, since we use an intermediary, we do not have internal evidence of the final FMIs on which it relies. In fact, our systems only map the intermediary's reference, while the references of the final FMIs are not tracked. As an example, we can cite Intesa San Paolo, which acts as an intermediary for Banca Mediolanum on all CSDs and most trading venues. In our systems, Intesa San Paolo is matched to all securities transactions, without specifying the final CSD. We currently report that we are still providing the above-mentioned information by requesting detailed data from our intermediaries. In this regard, we also note that our intermediaries will include our data in their reporting for individual FMIs, reporting us as their clients in these contexts.   Finally, we would like to take this opportunity to request clarification regarding some new items introduced starting this year, specifically: • Z 09.01/80 Operator of the FMI - is it correct to indicate the contractual contact person of the FMI/Intermediary? • Z 09.04/20 Product Type - Is it possible to include a description of the service provided by the FMI/intermediary, consistent with that indicated in item Z 09.01/220 - Services provided by FMI/intermediary, possibly with greater detail? • Z 09.04/30 Substitutability - Should the substitutability analysis be performed for all FMIs, considering as alternative FMIs/intermediaries only those with which a contract at the conglomerate level is already in place?  

  • 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_7702
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 13/03/2026

Z02.00_r0334 sum of net liability positions taking into account prudential netting rules

In accordance with Articles 429 and 295 of the CRR, only netting agreements that are legally recognised are eligible for consideration under prudential netting rules. With regard to standalone derivative positions that represent liabilities and are not subject to any netting agreement, is it correct to report these in r0334, even though they cannot be netted under the prudential netting framework?

  • 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_7697
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 13/03/2026

Z08.01 & Z08.02: Resolution resilience reporting

Should the explicit inclusion of clauses referred to in data points c0150 to c0170 of Z08.01-Template and c0100 to c0120 of Z08.02-Template be required only for contracts governed by third-country law, considering that contracts governed by EU law are deemed resolution-resilient by virtue of the implementation of BRRD requirements in the national legislation of Member States?

  • 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_7690
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 13/03/2026

Assigning risk-weight to a credit facility where the drawdown is contingent on non-credit risk related conditions that are required to be met by the obligor prior to any initial or subsequent drawdown and where the conditions for the drawdown are not met.

What risk-weight should be assigned to a credit facility where the drawdown is contingent on non-credit risk related conditions that are required to be met by the obligor prior to any initial or subsequent drawdown and where the conditions for the drawdowns are not met per the reporting date?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7722
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 13/03/2026

Treasury subsidiaries of non-financial corporates and “financial customer” definition

How should banks consider the “purpose” of treasury subsidiaries of non-financial corporates, when assessing whether the customer performs one or more of the CRD Annex I activities as its “main business”?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7734
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 10/03/2026

Definition of Default (CRR Article 178) – Application of contagion and the 20% “significant part” threshold in the presence of joint credit obligations where default is applied at facility level

When the Definition of Default for retail exposures is applied at facility level, how should institutions apply the contagion and pulling effects set out in Article 178 CRR and EBA/GL/2016/07 in the presence of joint credit obligations, given that paragraphs 96–99 are articulated for obligor level default, while Article 178 CRR allows default recognition at facility level. In particular: Should a joint obligor (i.e. a specific set of obligors jointly liable) be treated as a separate obligor for the purposes of assessing contagion and the “significant part” (20%) threshold? How should contagion be assessed between:  joint credit obligations of the same set of obligors, individual exposures of the obligors participating in the joint obligation, and other joint credit obligations of those individual obligors with different counterparties, where default is recognised at facility level (including defaults identified through indications of unlikeliness to pay)? How should this be applied in practice for the 3 illustrative examples given?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/07 - Guidelines on the application of the definition of default under Article 178 CRR
  • ID: 2026_7736
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 10/03/2026

Submiting Z06.00 on an individual basis in a separate template for every relevant legal entities (RLEs) in a resolution group

Why every single RLE  in a resolution group should report a separate Z06.00 “Deposit Insurance” template (LIAB 6) at individual level?

  • 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_7680
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 09/03/2026

Résolution 1 - Alimentation des cellules du Z03.01

We want to confirm how to fill the template Z03.01already reported by the entity in FINREP or COREP

  • 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_7669
  • Topic: Resolution plans
  • Date of submission:
  • Published as Rejected Q&A: 09/03/2026

Inconsistency between the report DPM table layout and data point categorization 4.2 and EBA Annex II Instructions.

'- In the DPM 4,2 file in tab Z_07.01.3 a and c, the fields 0100 (Number of transactions) and 0110 (Number of clients) are the components of the Cross Border Activities section. In the Annex II Instructions, the fields 0100 and 0110 are not subject to the Cross Border Activities section but they concern the number of clients and transactions of the total economic function. - In the DPM 4,2 file in tab Z_07.01.4, the fields 0090 (Number of counterparties) and 0100 (Number of transactions) are the components of the Cross Border Values section. In the Annex II Instructions, the fields 0100 and 0110 are not subject to the Cross Border Values section but they concern the total numbers of the total economic function.  Could you please confirm that the breakdowns in the tabs: Z_07.01.3a for the column 0100, Z_07.01.3c for the column 0110, Z_07.01.4  for the columns 0090 and 0100 are not included in the Cross Border section? 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7668
  • Topic: Resolution plans
  • Date of submission:
  • Published as Rejected Q&A: 09/03/2026