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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.

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List of Q&A's

Clarification on the use of external credit assessments when determining HQLA eligibility of assets representing a claim on a third-country central government

We seek clarification on the use of external credit assessments when determining HQLA eligibility under the provision of Article 10(c)(ii).  Specifically, where an asset representing a claim on a third-country central government has a residual maturity of less than one year: Can a short-term credit assessment from a nominated ECAI corresponding to Credit Quality Step 1 (CQS 1) be used for the purpose of determining eligibility as a Level 1 asset? Where both long-term and short-term credit assessments are available, which assessment should be used for the purposes of the HQLA eligibility assessment? More generally, we would be grateful for any guidance on the circumstances in which short-term external credit assessments may be used when assessing eligibility of assets for inclusion in the HQLA buffer under the LCR framework.

  • 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_7975
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 22/09/2026

Applicability of the prior permission requirement under Article 26(3) CRR to investment firms subject to Regulation (EU) 2019/2033 (IFR)

Article 26(3) CRR provides that institutions shall classify issuances of capital instruments as Common Equity Tier 1 (CET1) instruments only with the prior permission of the competent authorities. Article 2(5) CRR requires competent authorities to treat as "institutions", for the purposes of the CRR, only those investment firms to which Article 1(2) or 1(5) IFR applies (Class 1 firms). Investment firms subject to the IFR (Class 2 and Class 3 firms) apply the definition of CET1 capital by virtue of Article 9(1)(i) IFR, which refers to Part Two, Title I, Chapter 2 of the CRR. Do Class 2 and Class 3 investment firms require prior permission from their competent authority under Article 26(3) CRR in order to classify issuances of capital instruments as CET1 instruments?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7987
  • Topic: Capital requirements
  • Date of submission:
  • Published as Rejected Q&A: 22/09/2026

Classification of of CRR PSE under Finrep where local regulators identify them as a "non-CRR Bank"

Can a CRR PSE entity that qualifies as a Credit Institution under Article 4 of the CRR, be classified as a Credit Institution under FINREP, even if the local regulator classifies them as a "non-CRR Bank"?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7897
  • Topic: Supervisory reporting
  • Date of submission:
  • Published as Rejected Q&A: 22/09/2026

Instrument on unallocated Gold according to alternative standardised approach for market risk

Should the gold sensitivities of instruments related to unallocated gold, as calculated under the alternative standardized approach for market risk, be included in commodity risk or foreign exchange risk?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7993
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 22/09/2026

Spot instrument on unallocated Gold are subject to counterparty risk

Are spot instrument on unallocated Gold subject to counterparty risk?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7994
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 22/09/2026

Collateral haircuts for third-country equivalent PSE-RGLA’s

For the purposes of Article 197(2)(a) and (b) CRR, should the references to PSEs and RGLAs in Articles 115(2) and 116(4) CRR be interpreted as encompassing the third-country equivalent entities referred to in Articles 115(4) and 116(5) CRR, such that debt securities issued by those entities qualify for the treatment provided under Article 197(1)(b) CRR? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7989
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Use of the EBA’s aggregated loss data for “All national markets outside the Union” for the purposes of Articles 125 and 126 CRR.

Does the row “All national markets outside the Union” in the EBA publication Immovable-property loss data, Q4 2025 constitute a publication of loss-rate data that may be relied upon, in respect of immovable property situated in Switzerland, for the purposes of the loss-rate requirements referred to in Article 125(3), second subparagraph, and Article 126(3), second subparagraph, CRR? In particular, may an institution use the losses and exposure amounts reported in that aggregated row to assess whether the applicable loss-rate thresholds are met for exposures secured by residential or commercial immovable property situated in Switzerland, notwithstanding that Switzerland is not presented as a separate national immovable property market?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7980
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Treatment of the secured portion of defaulted IPRE exposures under the Standardised Approach

Under the Standardised Approach for credit risk, Article 127(3) CRR states that: "The exposure value remaining after specific credit risk adjustments of non-IPRE exposures secured by residential property or commercial immovable property in accordance with Articles 125 and 126, respectively, shall be assigned a risk weight of 100 % if a default has occurred in accordance with Article 178." Articles 125(2) and 126(2) establish dedicated treatments for income-producing real estate (IPRE) exposures through ETV-based risk-weight buckets. Following the CRR3 amendments, Article 127(3) explicitly refers only to non-IPRE exposures and does not specify the treatment of the secured portion of IPRE exposures after default.  Could the EBA clarify the prudential treatment of a defaulted IPRE exposure that satisfies all requirements of Article 124 and is secured by residential property or commercial immovable property? In particular: Should the secured portion of a defaulted IPRE exposure continue to be risk weighted according to the ETV buckets in Article 125(2) or Article 126(2), as applicable? Alternatively, should the secured portion of a defaulted IPRE exposure be reported in the exposure class "Exposures in default" and be assigned a risk weight of 100%, analogously to the treatment laid down in Article 127(3) for non-IPRE exposures, despite IPRE exposures not being explicitly referred to in that provision   If neither of the above approaches is correct, what is the appropriate risk-weight treatment and COREP reporting treatment for the secured portion of defaulted IPRE exposures under the Standardised Approach? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7979
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Application of the SME supporting factor to exposures financing private purposes following CRR III

Following the amendments introduced by Regulation (EU) 2024/1623 (CRR III), Article 501(2)(b) CRR defines an SME by reference to Article 5, point (9), CRR rather than to Commission Recommendation 2003/361/EC. Where the obligor is a natural person who carries out an economic activity and meets the turnover criterion in Article 5, point (9), should SME status be determined once at obligor level — so that the adjustment under Article 501(1) applies to all non-defaulted exposures to that obligor meeting Article 501(2)(a) — or should it continue to be assessed exposure by exposure by reference to the purpose of the individual financing, as set out in EBA Q&A 2021_6301?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7971
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

National competent authorities power to increase the quantity of ARTs and EMTS issuers' own funds or reserve assets in relation to Article 45(4)

Does Article 45(4) of Regulation (EU) 2023/1114 (MiCA) confer on national competent authorities or the EBA the power to require an ART or EMT issuer to increase the quantity of its own funds or reserve assets beyond the 1:1 backing established under Articles 36–38 of MiCA, or is the scope of Article 45(4) confined to requiring improvements to the composition, maturity and liquidity profile of reserve assets? More broadly, are the reserve and capital requirements that may be imposed on ART and EMT issuers under MiCA Level 1 capped by the mechanisms expressly provided for therein — in particular the bounded own-funds add-on mechanism of Article 35(5) following stress tests — such that national competent authorities or the EBA do not have discretion under Article 45(4) to impose open-ended or permanent structural overcollateralization or additional capital requirements beyond what MiCA Level 1 has expressly foreseen?

  • Legal act: Regulation (EU) No 2023/1114 (MiCAR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7968
  • Topic: Authorisation of issuers of ARTs and EMTs (MiCAR)
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

CVA exemptions: marginal impact of reintegration

Annex II of the ITS requires to show the marginal impact of reintegration of CVA exemptions, separately for each exemption. it defines the marginal impact as "the difference, expressed in absolute amount, between the relevant metric for the scope of transactions referred to in row 0010 after reintegrating the exemption, and the relevant metric for the scope of transactions referred to in row 0010".  This statement may in our opinion be interpreted in two different ways: For each of the 7 exemptions and for the whole portfolio including the exemptions, institutions are required to calculate the cva risk charge for the non-exempted portfolio + the relevant exemption separately and report the difference to the cva risk charge calculated for the non-exempted portfolio. This requires 8 separate calculations and the marginal impact of individual exemptions will be accurate. However, the marginal impact for the individual exemptions will not add up to the marginal impact for the whole portfolio. Institutions are required to calculate the difference of the cva risk charge calculated for the whole portfolio to the cva risk charge calculated for the non-exempted portfolio. This difference will be split up for the 7 exemptions using the contributions on counterparty level already calculated for the whole portfolio. This requires 1 separate calculation and the marginal impact for individual exemptions will add up to the marginal impact for the whole portfolio. However, the marginal impact of each individual exemption will be only approximate (i.e. scaled by counterparty contributions). Question: are institution allowed to use method (2)?

  • 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: 2026_7941
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Treatment of bank guarantees posted by clearing members as initial margin for the purpose of NICA in the CCP hypothetical capital (KCCP) calculation under Article 50a of EMIR

When a CCP calculates the hypothetical capital requirement (KCCP) pursuant to Articles 50a-50b of Regulation (EU) No 648/2012 (EMIR), as amended by Regulation (EU) 2019/876, applying the SA-CCR methodology set out in Part Three, Title II, Chapter 6, Section 3 of CRR, can bank guarantees provided by that clearing member be recognised as part of the collateral in the NICA term, provided that they are contractually pledged to the CCP and can be drawn upon in the event of the clearing member’s default? If the answer to Question 1 is negative and Article 276(1)(a) and (b) of CRR should be applied in full such that the only collateral eligible for inclusion in the NICA is that which qualifies as eligible financial collateral under Article 197 CRR (and Article 299 CRR for netting sets belonging entirely to the trading book), should a CCP assign a value of zero to bank guarantees posted by clearing members as initial margin when computing the Replacement Cost and the PFE multiplier? Or is there an alternative treatment available under the SA-CCR framework that would allow a CCP to partially or fully reflect the risk-mitigating effect of such guarantees in the EAD calculation?

  • Legal act: Regulation (EU) No 648/2012 (EMIR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7937
  • Topic: Market infrastructures
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Treatment of the Right Way Risk in Call Warrant

Is a call warrant issued by the counterparty  that is also the issuer of the underlying shares exempt from counterparty credit risk requirements?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7911
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Incorrect Quality Control check EGDQ_0764 for Annex I, INSTRUCTIONS FOR REPORTING ON SPECIFIC REQUIREMENTS FOR MARKET RISK, Template ({C90.00,r0010,c0080})

Data Quality ID EGDQ_0764 should be disabled as Total Assets reported in FRTB ({C90.00,r0010,c0080}) does not correspond to the amount reported in FINREP ({F01.01,r0380,c0010})

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/453 - ITS with regard to the specific reporting requirements for market risk
  • ID: 2026_7906
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Z08.0x The Service Identifier can only be set as an Integer instead of free text

Is it possible to apply the data type “free text” for the Service Identifier as specified in the Annex II IT Solution?

  • 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_7832
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Z08.04 The current key is incorrect in the ITS

Z08.04 The current key is incorrect in the ITS

  • 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_7831
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Validation rule v7511

validation rule v7511m Z_03.01, c, default: 0, interval: true}: {r0400} = {r0410} + {r0420} + {r0430} + max({r0440}, {r0450}, does not seem to be complete as it does not consider Z0.3.01 r0460

  • 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_7828
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Templates Z07.01.2 - Timing of substitution for Lending

Please confirm the time buckets to be used for reporting col 0130 'Timing of Substitution' in template Z07.01.02 FUNC1 Lending

  • 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_7827
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Templates Z9.03 - Null values reportable in col 0020 Segment

Please confirm what should be populated in Template 9.03 col 0020 Segment as the taxonomy does not allow null values whereas Annex II instructions specify this should be reported for CCPs only.

  • 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_7826
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Templates Z09.02 - 'Country 0030 ' and 'Critical functions ID 0040' for Essential FMIs

Please confirm what should firms populate in Template 9.02 columns 'Country 0030 ' and 'Critical functions ID 0040' for non-critical FMIs as these columns cannot have null values.

  • 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_7825
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026