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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

Template C 34.10 : Scope of exposures to be included in this template

Which of the below is the scope of exposures to be included for reporting in Template C 34.10: Option 1: Exposures to CCPs and exposures from CCP-related transactions; or Option 2: Only exposures to CCPs If the response is Option 1, please could you clarify in which rows should the exposures from CCP-related transactions be reported?

  • 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_7541
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2026

Sign convention of the Weighted Average Maturity in J 05.00

Should a negative Weighted Average Maturity be permitted for derivative instruments in template J 05.00 (both contractual and behavioural)?

  • 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_7565
  • Topic: Supervisory reporting - IRRBB
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2026

Article 12 of Regulation (EU) 2024/857 - non-performing exposures (NPEs) exceeds the 2% threshold.

Could the EBA clarify, in relation to the applicable reporting reference dates, from which point in time institutions are expected to implement and apply the corresponding model adjustment in their IRRBB reporting once this 2% threshold has been breached? Specifically, should the model change be reflected from the reporting period during which the threshold was exceeded, or from the beginning of the next full reporting period following the breach?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/857 - RTS on the IRRBB standardised approach
  • ID: 2025_7598
  • Topic: Supervisory reporting - IRRBB
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2026

Definition of Subordinated Debt holdings in Finrep vs COREP under CRR3

Could you please confirm whether, following the implementation of Regulation (EU) 2024/1623 of the European Parliament and of the Council amending Regulation (EU) No 575/2013 (Capital Requirements Regulation 3 – CRR3), institutions will be required to report subordinated debt holdings differently in FINREP and COREP.

  • 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_7637
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2026

Deduction of participations and Corep reporting

For the deduction under article 17 (1)(e), of RTS 241/2014, what is the correct COREP row for reporting this item? Is reporting under row 0529 “CET1 capital elements or deductions – other” appropriate? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions
  • ID: 2025_7642
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2026

Foreign Exchange Vega Risk Factors Definition

Shall the foreign exchange vega risk factors to be applied by institutions to instruments in the CVA portfolio sensitive to foreign exchange volatility be the implied volatilities of foreign exchange rates between the contractual currency pairs (i.e., no triangulation with respect to the institution’s reporting currency is required)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7650
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2026

Question regarding minimum requirements for Risk Committee attendance

Is there a minimum number of administrators required to be present for a risk committee dedicated to internal control to validly hold its meetings ? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/05 - Guidelines on internal governance under CRD - repealing EBA/GL/2017/11
  • ID: 2026_7685
  • Topic: Internal governance
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2026

Clarification Request Regarding Validation Rule 6514_m for LDR Template T.04 and Its Comparison of Own Funds with Outstanding Principal Plus Accrued Interest

For example, for financial instrument measured at fair value, the inclusion of hedge adjustments (which may either increase or decrease the measured value) may cause the amount recognized as own funds to be higher than the simple sum of outstanding principal and accrued interest. This could lead to a breach of Validation Rule 6514_m.Given these developments, discrepancies may now arise due to the inherent variability introduced by the updated valuation adjustments.

  • 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
  • ID: 2025_7516
  • Topic: Interactions with the CRR / CRD IV and the BRRD
  • Date of submission:
  • Published as Rejected Q&A: 30/01/2026

Z 09.04 FMI 4 - Multiple alternative providers

Regarding the final ITS for Resolution Reporting there's an additional Template for FMI module: Z 09.04 FMI 4.In case of multiple alternative providers, should all of them be included? If not, which is the supervisor criteria to select only one of the alternative providers?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7464
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 30/01/2026

Calculation of the unmargined exposure value for a netting set with multiple margin agreement or including both transaction subject to a margin agreement and transaction not subject to a margin agreement

How to calculate the capped exposure value, i.e., the exposure value of the netting set in the event that it is not subject to any type of margin agreement, when there are multiple margin agreements applicable to this netting set or when this netting set includes both transactions subject to a margin agreement and transactions not subject to a margin agreement? For the calculation of the unmargined value, should all deals be included in a single sub-netting set (the one containing contracts not subject to margining) and not divided as required by paragraph 4 of Article 274, or should the sub-netting sets remain separate and their value be calculated as if they were unmargined?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7649
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 26/01/2026

Template C90.00 and C90.05

For the purpose of determining the "On- and off-balance sheet business subject to market risk" for template C90, is the netting between long and short positions in the same exact instrument allowed? 

  • 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: 2025_7647
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 26/01/2026

Inconsistency in the formulation of conditions for Hard Tests

Can Art. 199 para. 3, para. 4 CRR be interpreted in line with amended Art. 125 para. 2 sub-para. 3 and para. 3 sub-para. 1 6, 126 para. 2 sub-para. 3 and para. 3 sub-para. 1, 199 para. 4a CRR; hence, is it sufficient that a member state’s competent authority publishes loss rates despite different wording in Art. 199 para. 3, 4 CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7437
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 26/01/2026

Use of short-term issuer credit assessments under Article 131

May short-term issuer ratings be used to derive risk weights for unrated short-term exposures in the context of Article 131 CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7687
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 26/01/2026

reverse solicitation

The reverse solicitation is where a client or counterparty approaches an undertaking established in a third country at its own exclusive initiative for the provision of banking services, including their continuation, or banking services closely related to those originally solicited.  Is the invitation letter from the agent bank who arranges for the syndicated loans or Schuldscheindarlehen ("SSD") a sufficient supporting document to evidence that a client approaches us at its own exclusive initiative? Or an independent declaration directly made from the borrower (the client) is required?  

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7665
  • Topic: Passporting and supervision of branches
  • Date of submission:
  • Published as Rejected Q&A: 22/01/2026

Alternative treatment and SME support factor

If an institution uses the alternative treatment i CRR3 article 230 (4), does the exposure then qualify to use the SME supporting factor?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7682
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/01/2026

Applying the provisions of Article 390 (7) CRR and Delegated Regulation 1187/2014 for determining the overall exposure to a client or a group of connected clients in respect of transactions with underlying assets for received collaterals (indirect exposures) after applying substitution approach according to Article 403 CRR 

Does a credit institution have to apply the provisions of Article 390 (7) CRR in combination with Delegated Regulation 1187/2014 to a securitization or investment fund exposure, when the credit institution received the securitization or investment fund exposure as a collateral in an SFT?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1187/2014 - RTS for determining the overall exposure to a client or a group of connected clients in respect of transactions with underlying assets
  • ID: 2025_7661
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 13/01/2026

I couldn´t find this question.

We request EBA’s clarification on the application of Article 402 CRR to exposures fully secured by commercial property classified as IPRE under CRR III, but risk‑weighted as non‑IPRE in accordance with the exemption defined in Article 126(2) because the property meets the national conditions applicable in Sweden (the so‑called “hard test”). Specifically: 2.1 Eligibility for Article 402 when collateral is IPRE by classificationDoes the collateral’s IPRE classification affect eligibility for the Article 402 exposure value reduction, specifically for large exposures where the risk-weighting due to the exemption in Article 126(2) is treated as non-IPRE due to national conditions in Sweden (the so-called “hard test”) 2.2 Treatment under Swedish national conditionsIn cases where national authorities allow commercial IPRE collateral to be risk-weighted as non-IPRE under Article 126(2) (Swedish hard test), can the bank apply the Article 402 reduction, assuming all CRM requirements under Articles 399, 208, and 229 are satisfied? In other words: Does Article 402 eligibility follow the risk-weighting treatment under Article 126.2, or does it follow the classification of the collateral under CRR III?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7670
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 13/01/2026

Template 2 - EBA validation rules v89325_m and v89326_m

The formula linked to the following rule IDs: v89325_m and v89326_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_7633
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 12/01/2026

Pillar 3 Template EULR2 - LRCom: Leverage ratio common disclosure (Row 24) Instruction

Pillar 3 Template EULR2 - LRCom: Leverage ratio common disclosure (Row 24) Instruction In the current instruction for Row 24, it states: “Sum of amounts in rows 7, 13, 18, 22, and EU-22k of EU LR2 – LRCom.” However, based on the latest EBA mapping table/logic, the correct reference should be: LRCom (sum of rows 7, 13, 18, 22, EU-22m). This aligns with our understanding that the correct row is EU-22m, not EU-22k. Could EBA please update the instruction accordingly?

  • 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_7620
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 12/01/2026