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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 Z08.01: Reporting on intra-group services with identical LEI codes

Per EBA taxonomy, concatenation of col 0005, 0010, 0020, 0040, 0060 and 0130 in Template 8.01 should be unique (unique key).  This causes duplication error across rows reporting similar intra-entity services between different branches, i.e. identical providers/receiver codes and identical other fields required for unique key.Does the taxonomy need to be amended to allow such reporting?

  • 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_7822
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Historical valuation series considered in determining the average value of real estate collateral

Considering that institutions may rely on comparable real estate valuation indices to fill in periods where no formal property revaluation exists, in order to construct the required equally distant interval valuation points, is there any requirement or expectation to extend the historical series beyond the minimum three data points, covering the full reference period (e.g., six years for RRE and eight years for CRE)?  The reasoning underlying this question is illustrated in the following example: RRE: Case 1 - Exclusive reliance on three data points derived from formal property revaluation exercises Period 0: Property value at origination Period 1: -- Period 2: -- Period 3: First formal property revaluation Period 4: -- Period 5: -- Period 6: Second formal property revaluation RRE: Case 2 - Use of real‑estate price valuation indices to construct the historical period Period 0: Property value at origination Period 1: First property value collected using real‑estate valuation indices Period 2: Second property value collected using real‑estate valuation indices Period 3: Third property value collected using real‑estate valuation indices Period 4: Fourth property value collected using real‑estate valuation indices Period 5: Fifth property value collected using real‑estate valuation indices Period 6: First formal property revaluation RRE: Case 3 - Use of real‑estate price valuation and indices to construct the historical period Period 0: Property value at origination Period 1: First formal property revaluation Period 2: First property value collected using real‑estate valuation indices Period 3: Second property value collected using real‑estate valuation indices Period 4: Third property value collected using real‑estate valuation indices Period 5: Fourth property value collected using real‑estate valuation indices Period 6: Second formal property revaluation

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7810
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Application of the current market value as a cap for immovable property collateral

Should the most recent market value constitute the maximum permissible (“cap”) for prudential purposes, even when the revaluation mechanisms under Article 229 would otherwise yield a higher value?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7809
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Historical valuation data predating the origination of the exposure for eligible immovable property collateral

For the purpose of calculating the average property value for exposures where the available valuation history does not meet the minimum historical period of six years for residential real estate (RRE) and eight years for commercial real estate (CRE), may the missing historical period be supplemented by using real estate price valuation indices for comparable properties predating the origination date of the exposure?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7762
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

DPM 4.2 Resolution Planning reporting Template Z12 Treatment of the “Instrument Type” field

With reference to the DPM 4.2 Resolution Planning reporting framework and, in particular, to Resolution Plan Template Z12, field “Type of instrument”, could you confirm the correct classification of the instruments listed below under the Italian jurisdiction for reporting 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: 2026_7694
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

DPM 4.2 – Correctness of identical cells between C 25.01.a and K 60.00

For DPM 4.2 the cells {C_25.01.a, r0010, c0020} and {K_60.00.a, r0120, c0030} are identified as identical, have the same assigned VariableID and the same defining DPM properties. Considering the instructions for reporting data in these cells different values are expected.

  • 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_7692
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Type of exposures to report on r0152 of C10.00 COREP Template

Considering the scope of the row 0152 on C10.00 template, does the exposures that should be reported refer to UNSECURED exposures?

  • 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_7689
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

J 09.00.a : Column 020 of lines 160, 220 and 300

Please note that column 020 of lines 160, 220 and 300 of report J 09.00.a should have the same data points as those of report J 08.00.a, as is the case for column 010.  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7656
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Validation Rule RRCOROF_V903610_H_C0030

Could you please clarify the validation rules newly introduced or reactivated in template C34.03 within COROFI and COROFC as of 31 March 2026? These rules require that the totals for Number of Transactions (RRCOROF_V903610_H_C0030_S0001), Nominal Amount (RRCOROF_V903610_H_C0040_S0001), Positive Market Value (RRCOROF_V903610_H_C0050_S0001 ) and Negative Market Value (RRCOROF_V903610_H_C0060_S0001)  and Add-on (RRCOROF_V903610_H_C0070_S0001) equal the sum of the respective risk categories (Interest Rate Risk, Foreign Exchange Risk, Credit Risk, Equity Risk, Commodities Risk, Other).     

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7910
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 31/08/2026

Methodology for calculating the scenarios referred to in Article 25(2), (3), and (4), as well as point 5(a), (b), and (c) of the Annex to the Regulation.

Our Bank as another non-listed institution, as part of the CRR Regulation, is required to apply the "standardized approach" for interest rate risk, as defined in Regulation 2024/857. Banks subject to the simplified standardized methodology apply, by way of derogation from Article 8(9), the pass-through rate specified in point 5(a), 5(b), and 5(c) of the Annex. Our Bank, as another non-listed institution, should independently calculate the pass-through rate, taking into account the Bank's historical data for the base scenario and scenarios predicting a decrease and an increase in short-term interest rates. Currently, the Bank applies the pass-through rate from points 5a, 5b, and 5c of the Annex to the Regulation. Since the UKNF has issued a recommendation that the Bank independently determine the pass-through rate, please provide the methodology for calculating the scenarios referred to in Article 25(2), (3), and (4), as well as point 5(a), (b), and (c) of the Annex to the Regulation.

  • 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: 2026_7933
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 11/08/2026

Geographical location for securitisation exposures (and CIU exposures) where underlying exposures span multiple countries

How should securitisation exposures, where the underlying exposures originate from multiple countries, be allocated for the purposes of determining the institution‑specific countercyclical capital buffer? In particular, should Article 4(1) of Delegated Regulation (EU) 2014/1152 be interpreted as: Option A: applying only when all underlying exposures relate to obligors in a single jurisdiction, with Article 4(2) automatically and mandatorily applying whenever more than one country is represented, or Option B: establishing a look‑through approach, under which the securitisation exposure is allocated proportionally to the distribution of underlying obligors across countries, with Article 4(2) serving as an (optional) simplification (allocation to the largest‑share country) that institutions may choose instead?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1152/2014 - RTS on the identification of the geographical location of relevant credit exposures for institution-specific countercyclical capital buffer rate
  • ID: 2026_7790
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 06/08/2026

ESG P3 - Template 1 - NACE I classification

The formulas linked to the following rule IDs: v12723_m and v12724_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_7648
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Validation rule v89319_m is not correct

Validation rule v89319_m is incorrect for c0110. Percentages cannot be summed up.

  • 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_7657
  • Topic: Supervisory reporting
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Validation rule v89325_m is not correct

Validation rule v89325_m should be deleted as it is not in line with reporting guidance and inconsistent with corresponding P3 data hub validation rules.

  • 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_7658
  • Topic: Supervisory reporting
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Scope of reporting in Z01.01

Please clarify which scope of consolidation should be applied within the reporting template. Please clarify as well how the reconciliation to the respective measures should be performed depending on the first clarification. 

  • 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_7663
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

ESG P3 - Template 1 - validation rule v89257_m

Is the validation rules v89257_m correctly defined?

  • 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: 2026_7780
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

FINREP Identical Cells 5458783, 5458788, 5459395, 5460187

Could the EBA confirm whether these identical cell checks are correct? If not, should they be updated to align with the previous logic (v8610_i, v8611_i, v10006_i, v10007_i) to ensure consistency between templates and definitions?Please clarify the intended scope of collateral reporting in these templates and whether the current rules will be revised.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7788
  • Topic: Supervisory reporting - Other
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Template F 13.2.1.c VariableID 433471 and 433464

Following the most recent update to the FINREP validation framework under Reporting Framework 4.2., a new data point categorization has been introduced affecting template F 13.2.1.c, specifically Variable IDs 433471 and 433464. We would appreciate confirmation as to whether this data point categorization has been correctly defined and, if so, clarification on the prudential reporting rationale underlying it. Our concern is that the validation may not be conceptually appropriate in all cases, as not all additions of foreclosed assets necessarily qualify as non-current assets held for sale.

  • 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: 2026_7904
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Reporting obligations under Article 3 of the CIR

Whether, and to what extent, will the reporting obligations concerning Relevant Legal Entities (RLEs) under Article 3 of the CIR also apply where a recently acquired RLE is expected, with a high degree of certainty, to cease to exist as a legal entity prior to the adoption of the resolution plan as a result of a legal merger. Additionally, how should this acquired entity be treated for the purposes of resolution planning and related reporting obligations during the interim period between its acquisition and its absorption through merger? We wonder if resolution authorities (RAs) may waive the reporting obligations for this acquired entity for the first reporting cycle after acquisition. Against this background, does the framework require or allow a reclassification of the acquired entity (which used to be a Liquidation entity before acquisition with no reporting obligations) as an RLE immediately upon acquisition, implying inclusion in the group’s resolution plan and submission of the applicable reporting templates? Alternatively, may the acquired entity continue to be treated as a liquidation entity until the legal merger is completed, with its status and standalone reporting obligations remaining unchanged during the interim period? Clarification is sought on whether, in the context of M&A transactions, resolution authorities are expected to adjust the entity’s classification upon acquisition, or whether they may maintain the pre-acquisition status until legal integration is finalised.

  • 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_7918
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Classification of spread components of floating-rate instruments for contractual repricing reports

How should institutions classify the fixed spread component of a floating-rate instrument when reporting IRRBB repricing cash flows? Article 7 of Commission Implementing Regulation (EU) 2024/857 requires institutions to allocate the spread components of floating-rate instruments "up to the final contractual maturity, irrespective of any repricing of the non-amortised principal". However, Annex V, Section 3, states that the distinction between fixed-rate and floating-rate instruments is to be applied at instrument level. Under this definition, an instrument whose interest payments are contractually linked to an external benchmark is classified as a floating-rate instrument. In practice, two alternative interpretations have emerged: Cash-flow level interpretation: the fixed spread component of a floating-rate instrument is treated as a fixed-rate cash flow extending until contractual maturity and therefore reported within the fixed-rate section of the repricing templates. Instrument level interpretation: the spread component remains associated with the floating-rate instrument and is therefore reported within the floating-rate section, even though Article 7(c) requires the spread cash flows to be allocated up to final maturity. Should institutions report the spread components of floating-rate instruments in the fixed-rate section because they are allocated until final contractual maturity under Article 7(c), or should they remain in the floating-rate section because the fixed/floating classification applies at instrument level according to Annex V?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
  • ID: 2026_7940
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026