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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.

List of Q&A's

Incoherent formulae of the validation rule v90315_m

The control formula currently in place for column 0070 / row 0260 of template C16.02 does not seem aligned with your definition of this indicator. Could you clarify the expected logic?

  • 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

Incoherent formulae of the validation rule v90316_m

The control formula currently in place for column 0070 / row 0310 of template C16.02 does not seem aligned with your definition of this indicator. Could you clarify the expected logic?

  • 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

Incoherent formulae of the validation rule v90317_m

The control formula currently in place for column 0070 / row 0340 of template C16.02 does not seem aligned with your definition of this indicator. Could you clarify the expected logic?

  • 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

C 14.00, column 0040 Securitisation Type

How should a credit institution populate column 0040 of COREP table C 14.00 in the event that (i) the transaction has all the characteristics to meet the definition of ‘securitisation’ as defined in point (1) of Article 2 of Regulation (EU) 2017/2402, and; (ii) the transaction does not fully satisfy the definition of any of the securitisation types available to select from on the reporting form. For example, a transaction that meets the definition of ‘securitisation’ per point (1) of Article 2 of Regulation (EU) 2017/2402 and whose structure closely resembles that of a traditional securitisation, however does not involve an SSPE (i.e. the transfer of the economic interest in the exposures being securitised occur directly between originator and investor / sponsor).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Form ‘F 32.01’ on asset encumbrance: Market value including or excluding accrued interest?

Ist im Bogen „F 32.01“ zur Asset Encumbrance der Marktwert inklusive oder exklusive Stückzinsen auszuweisen? In form ‘F 32.01’ on asset encumbrance, should the market value be reported including or excluding accrued interest?

  • 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

incoherent formulae

Is the v90304_m control formula consistent with the other controls on C16.02 ?

  • 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

incoherent formulae

Should the v903188_s control apply for establishments that do not supply the C16.04 status?

  • 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

incoherent formulae

Should the v903188_s control formula apply to columns 0010 and 0020?

  • 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

PILLAR 3 - form EU CMS2 mapping for row EU 7d: Categorised as subordinated debt exposures in SA

According to official mapping for row EU 7d: Categorised as subordinated debt exposures in SA, column "d" and "EU d" include form c07-qx2062 that refers to CRE IPRE OTHER. Is intention to see CRE IPRE OTHER , or maping should be changed and include subordinated debt exposures?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/14 - Guidelines on materiality, proprietary, confidentiality and disclosure frequency under Pillar 3

PILLAR 3 - form EU CMS2 mapping for columns d and EU d

According to mapping, column “d” and “EU d” refers to c07 and c10. Some of cells in column “d” and “EU d” refers only to c10. Please, could you explain the reason to exclude c07 from some cells in column “d” and “EU d”?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/14 - Guidelines on materiality, proprietary, confidentiality and disclosure frequency under Pillar 3

Definition of "official export credit agency" for the calculation of deduction for non-performing exposures

Article 47c(4a) of the CRR exempts the part of a non‑performing exposure guaranteed or insured by an “official export credit agency” (ECA) from the deduction requirements laid down in Article 47c. However, the CRR does not define the term “official export credit agency”. In this context, what are the criteria for qualifying as an “official export credit agency” and how can it be determined whether an export credit agency and the guarantee or insurance provided meets the criteria for applying the derogation as provided in CRR Article 47c(4a)?

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

Execution of an authorized payment instruction made conditional on manual user redirection

If an Account Servicing Payment Service Provider (ASPSP) makes the execution of a payment instruction, already successfully authorized via Strong Customer Authentication (SCA) in its app, conditional on the Payment Service User (PSU) subsequently manually returning from the ASPSP's authentication app back to the Third Party Provider's (TPP) environment, does this condition constitute an obstacle under Article 32(3) of the RTS?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication

Obstacle assessment of requiring multiple manual checkboxes for a single AIS consent

Does the practice of an ASPSP requiring a PSU to manually tick multiple, separate checkboxes for different categories of account data in order to grant a single consent for an Account Information Service (AIS) constitute an obstacle under Article 32(3) of the RTS, by adding unnecessary steps and friction to the user journey?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication

Obstacle assessment of requiring an additional SCA for PIS within an existing authenticated AIS session

If a Payment Service User (PSU) initiates a payment (PIS) immediately after establishing a session for an Account Information Service (AIS) (for which SCA has already been performed), does the ASPSP's requirement for an additional, separate SCA—such as the need to fully log in to the mobile banking app before the payment confirmation screen is displayed—solely to access the payment function (and preceding the dynamic linking SCA) constitute an obstacle under Article 32(3) of the RTS?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication

Obstacle assessment of an ASPSP offering only web redirection to TPPs while a superior native app authentication method exists for its direct users

Does an Account Servicing Payment Service Provider's (ASPSP) decision to offer only a web-based redirection for Third Party Provider (TPP) initiated journeys constitute an obstacle under Article 32(3) of the RTS, if that ASPSP also makes available a more convenient, direct authentication procedure in its native mobile application for its Payment Service Users (PSUs) when they access their accounts directly?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication

Definition of ‘another financial entity’

What types of entities should be regarded as ‘another financial entity’ for the purposes of article 17 (2) of the IFR?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Consideration of the row 0610 of the NSFR template C 80.00 in Disclosure template EU LIQ2 following published EBA Mapping tool

In the Mapping tool published according to the EBA Reporting framework 4.1, for determining the Pillar 3 Disclosure template EU LIQ2 - Net Stable Funding Ratio, row 0610 (non-HQLA securities encumbered for a residual maturity of one year or more in a cover pool) of the template C 80.00 - NSFR - REQUIRED STABLE FUNDING  is assigned twice. The assignment is made to the EU LIQ2 template row EU-15a (Assets encumbered for a residual maturity of one year or more in a cover pool) and indirectly to row 24 (Other loans and securities that are not in default and do not qualify as HQLA, including exchange-traded equities and trade finance on-balance sheet products) through the assignment of the summary row 0560 of the NSFR template C 80.00. We would kindly ask you for the confirmation of such representation. 

  • 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

Supervisory obligations of NCAs under Article 32(2) of Commission Delegated Regulation (EU) 2018/389

Article 32(2) of Commission Delegated Regulation (EU) 2018/389 states that competent authorities shall monitor the interfaces, the indicators and subject them to stress testing. We are seeking clarification on the interpretation of this provision. In particular, we would appreciate guidance on the EBA’s expectations regarding the scope and nature of NCAs’ monitoring of these interfaces, including the assessment of their operational performance and reliability, as well as the conduct of stress tests, to ensure that the requirements of Article 32(1),that dedicated interfaces shall maintain the same level of availability and performance as the ASPSP’s own online channels, are effectively met.

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication

Requirement for ASPSPs to comply with standardized communication protocols under Article 30(3) of Commission Delegated Regulation (EU) 2018/389

Under Article 30(3) of Commission Delegated Regulation (EU) 2018/389, ASPSPs are required to follow communication standards issued by international or European standardisation organisations.In this context, we seek clarification on whether, when an ASPSP has chosen to adopt a recognized communication standard issued by a European or international standardisation body (such as ISO 20022) for its PSD2 interfaces, the standard is expected to be applied consistently and in accordance with its specifications across all such interfaces, regardless of internal documentation or subsequent clarifications issued by the ASPSP, which may reflect internal implementation approaches rather than the standard itself.

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication

Introduction of additional mandatory steps or redirections in PISP payment initiation flows

In accordance with Article 32(3) of the RTS on SCA and CSC, may an ASPSP impose mandatory additional steps or redirections (pre-step) in a redirection-based payment initiation flow through a PISP, where such steps or redirections do not form part of the payment initiation process experienced by the PSU when using the ASPSP’s own mobile or online channels?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication