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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

Definition and Scope of DORA

Does the definition of 3.19 include all service providers - no matter the relevance of their service for the digital resilience of the financial service e.g. providers of an employee survey tool or a recruitment tool, where the absence of their services would no have no impact on the resilience security of network and information systems supporting the business processes of financial entities. If in the affirmative, does this mean that any ICT third-party service provider falls within the scope of DORA ( see Article 2.1(u). As a consequence a service a digital employee exercise app provider will fall within the scope of DORA if they sell their services to a financial service provider? If in the affirmative, is this proportionate with regard to the impact that this has on ICT third-party service providers whose services have no impact on the security of network and information systems supporting the business processes of financial entities. If in the affirmative, do the financial authorities now have competence over all ICT third-party service providers, regardless of what kind of services they provide as long as they are providing services to a financial entity? * financial entity = or any other entity besides an ICT service provider

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7421
  • Topic: ICT third-party risk management
  • Date of submission:
  • Published as Rejected Q&A: 04/09/2025

Annual Report to the Competent Authorities on new Arrangements for the use of ICT services

Pursuant to the provisions of Chapter V, Section I, Article 28, Paragraph 3, of the DORA Regulation, which states “Financial entities shall report at least yearly to the competent authorities on the number of new arrangements on the use of ICT services, the categories of ICT third-party service providers, the type of contractual arrangements and the ICT services and functions which are being provided.,” we kindly request clarification on whether this provision requires a separate and specific communication in addition to the Register of Information, or whether the communication of such data is already fulfilled through the annual submission of the same Register, constituting a single compliance obligation. In the event that a separate communication is required in addition to the annual submission of the Register of Information, we kindly request clarification on the meaning of the term "categories of third-party ICT service providers" as mentioned in Article 28, Paragraph 3 of the DORA Regulation.

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7531
  • Topic: ICT third-party risk management
  • Date of submission:
  • Published as Rejected Q&A: 04/09/2025

ANNUAL REPORT ON NEW ARRANGEMENTS ON THE USE OF ICT SERVICES

Pursuant to the provisions of Chapter V, Section I, Article 28, Paragraph 3, of the DORA Regulation, which states: “Financial entities shall report at least yearly to the competent authorities on the number of new arrangements on the use of ICT services, the categories of ICT third-party service providers, the type of contractual arrangements and the ICT services and functions which are being provided.,” we kindly request clarification on whether this provision requires a separate and specific communication in addition to the Register of Information, or whether the communication of such data is already fulfilled through the annual submission of the same Register, constituting a single compliance obligation. In the event that a separate communication is required in addition to the annual submission of the Register of Information, we kindly request clarification on the meaning of the term "categories of third-party ICT service providers" as mentioned in Chapter V, Section I, Article 28, Paragraph 3 of the DORA Regulation.

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7468
  • Topic: Other DORA topics
  • Date of submission:
  • Published as Rejected Q&A: 04/09/2025

DPM 3.5 - Diversity Benchmarking - v22547_a & v22587_m

One of our client is having some trouble reporting the diversity benchmarking for two reasons : a_ Validation v22547_a  The validation v22547 only allows the value (ZZ:x784) Yes & (ZZ:x785) No to be entered on the row r0020 of report R1900 where the annotated templates allows additionaly the value Not applicable. Our client thinks it's incorrect as the value Not applicable should be possible. "We can see that the cells provide a dropdown menu with 3 options, and it is specified that we have [The regions where the institution or investment firm is active (subsidiary/branch/cross-border basis with material business activities) should be selected (Yes/No). For the categories of executive or non-executive directors it should be indicated (yes/no/non-applicable) if at least one director has one of their geographical provenances, that spans at least a period of three years, from the corresponding region. Non applicable should only be selected, where there are no non-executive directors in the case of investment firms or employee representatives. Where the actual location a member gained geographical provenance is in more than one of the specified regions, the member should be allocated to the most relevant regions on a best effort basis (e.g. a Member that lived in Istanbul may select Europe, Asia or both regions) ] Can you help us answering the client on the fact that the value "Not applicable" should or not be used on the row 0020.   b_ Validation v22587_m On report R22.02 our client has only define a target for Non executive director, so it as has filled : Report R2202 the following way :     Executive directors Non-executive directors     0010 0020 Target  % set in percentage (two digits e.g. 33.33%) in the diversity policy, including in cases where this is applicable under national law  0010   40,0000 Target expressed as minimum headcount in the diversity policy (number of members) 0020     Compliance with internal policy: Has the target been met at the reference date? 0030   Yes And as set in the report R2201 that the "Targets set only for the management body in the supervisory function (non-executive directors)" SCOPE: For which scope of members of the management body are gender diversity targets set? (please select from drop down menu) 0130 Targets set only for the management body in the supervisory function (non-executive directors) By filling the report like this it triggers the validation V22587 indeed this validation will always be trigered where Report R2201 and R2202 are filled and when value in R0022.020 in R0010 C0010 is different that R0022.020 in R0010 C0020 and when the value in R2201 R0130 <> Different targets set for the management and supervisory function of the management body As in our case the target has only be set for the Non exucitive director we think it 's correct to use the value "Targets set only for the management body in the supervisory function (non-executive directors)" in report R2201, and to fill only the column 0020 in report R2202 but by doing that we will have a different value between R0022.020 in R0010 C0010 is different that R0022.020 in R0010 C0020 causing an unexpected anomaly. Can you please investigate if the the control is correct?      

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2023/08 - Guidelines on the benchmarking of diversity practices, including diversity policies and gender pay gap
  • ID: 2025_7430
  • Topic: Remuneration
  • Date of submission:
  • Published as Rejected Q&A: 04/09/2025

Application of real estate valuation principles to AIRB

Are the valuation principles per CRR 229.1(e) (capping to 6/8-year averages) applicable when using own estimates of LGD (AIRB)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7405
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 02/09/2025

Data quality scans and connected data corrections as model changes

Has the implementation of data quality scans to be treated as a change of a rating system in accordance with art 142 I CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7497
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 01/09/2025

Clarification Request on Eligibility of Agricultural Land and Forests as Collateral for RWA Purposes under CRR

Dear Sir/Madam, We are seeking clarification regarding recent changes introduced by the EBA concerning the eligibility of agricultural land and forests as collateral for the purposes of calculating Risk-Weighted Assets (RWA) under the CRR framework. According to the updated EBA interpretation, agricultural land and forest land may be treated as eligible collateral, provided they are insured. However, in Croatia, insurance coverage exists only for crops—not for the land itself. This creates a significant implementation challenge, particularly for forest land, which does not contain insurable crops at all, making it impossible to obtain the required insurance. In light of this, we kindly request clarification on the following points: Can agricultural or forest land be treated as eligible collateral under CRR if the required insurance cannot be obtained due to a lack of available insurance products in the local market? Does the absence of crop-related insurance for forest land entirely preclude its recognition as eligible collateral, even if it meets all other requirements (e.g. enforceability, valuation, and monitoring)? How should institutions proceed when collateral types are deemed eligible by the EBA but cannot be insured in practice due to market limitations? Is there flexibility within the CRR framework to accommodate cases where key eligibility conditions (such as insurance) are not achievable despite best efforts, or are alternative treatments available for such exposures? We would appreciate your guidance and any references to applicable CRR articles or relevant EBA Q&A that may clarify how to proceed in such cases.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 183/2014 - RTS for the calculation of specific and general credit risk adjustments
  • ID: 2025_7495
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 01/09/2025

Risk weighting attributed to gold in the form of a commodity such as jewellery items for pawn credit business

Pursuant to the new definition of gold bullion under Article 4(1)(60a) of CRR, can gold in the form of jewelry items taken as collateral in a pawn loan qualify as "gold" and thus be eligible for prudential treatment in accordance with Article 134 CRR for the value based on the gold content (purity × mass), with no allowance for artistic, numismatic, branding or other extrinsic attributes to such jewelry?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7491
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 01/09/2025

Calculation of Kirb

According to Article 255(2)(3), Kirb seems to be defined as (EL+UL)*8%/exposure value of the underlying pool. However, considering the fact that, for unexpected loss, banks hold an amount of regulatory capital by UL*8%, but for expected loss not covered by provisions, banks have to deduct it from Tier 1 capital,  As Kirb stands for the averaged capital requirement of the underlying exposures(including expected loss), it should be calculated as (UL*8%+EL)/exposure value of the underlying pool instead.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7368
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as Rejected Q&A: 01/09/2025

Report charges and rejections

Hello, when will you publish the report specification result of the consultation ?

  • Legal act: Regulation (EU) 2024/886 (IPR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7304
  • Topic: Instant payments
  • Date of submission:
  • Published as Rejected Q&A: 28/08/2025

Own Funds Requirements before Securitisation (%) Ksa

Validation v11650_m states that for the positions reported in the C14.00 template that are not Covered Bonds or Other Liabilities, Own Funds Requirements before Securitisation (%) Ksa (c0223) should be reported. However, is this validation applicable if the positions are issuer loans (held to meet the securitisation risk retention requirements) and the very purpose of the issuer loan is to hold a 5% vertical slice – it is not subject to any credit trenching?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • 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: 2024_7181
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as Rejected Q&A: 28/08/2025

Pillar 3 Disclosure: Template EU CQ1: Credit quality of forborne exposures (Col e & f; R090 Loan commitments given ) - Clarification on Mapping Logic

According to the EBA mapping: (Col e & f ; R0090) for row “Loan commitments given” under impairment section are mapped to template F19, which is presented as a positive value in CR1. However, our understanding is that impairment values should be disclose as negative figures in CQ1. Please confirm whether this interpretation is correct. 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7546
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 21/08/2025

Pillar 3 Disclosure: Template EU CR1: Performing and non-performing exposures and related provisions (Column g-l; R150-210 Off balance sheet exposure) - Clarification on Mapping Logic

According to the EBA mapping, columns g to l (rows R150–R210) for off-balance sheet exposures are mapped to template F18, which would be presented as a positive value in CR1. However, our understanding is that impairment values should be disclose as negative figures in CR1. Please confirm whether this interpretation is correct.  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7545
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 21/08/2025

factor to apply to non performing exposures to which a risk weight is 0% in a performing situation for the purpose of calculating the amount of unsufficient coverage

is it possible to consider that the derogation applied to the part of the non-performing exposure guaranteed or counter-guaranteed by an eligible protection provider referred to in Article 201(1), points (a) to (e), the unsecured exposures to which would be assigned a risk weight of 0 % under Part Three, also applies to unsecured exposures themselves when assigned a risk weight of 0% ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2018/06 - Guidelines on management of non-performing and forborne exposures
  • ID: 2025_7529
  • Topic: Credit Risk – Non performing exposures / loan origination
  • Date of submission:
  • Published as Rejected Q&A: 21/08/2025

Pillar 3 Disclosure - EU OV1 – Row 1 ‘Credit risk (excluding CCR)’ mapping clarification

In Template EU OV1, Row 1 "Credit Risk (excluding CCR)", we observe that the current mapping includes the following components from C 02.00: {C 02.00, r0690, c0010} – Other risk exposure amounts minus {C 02.00, r0720, c0010} – Requirements for large exposures minus {C 02.00, r0755, c0010} – Additional RWEA for market risk imposed by supervisor (Art. 110) minus {C 02.00, r0770, c0010} – Additional RWEA for market risk minus {C 02.00, r0780, c0010} – Transitional RWEA for crypto assets (Art. 501d(2))   While this mapping appears to isolate the portion of "Other RWA" not related to market risk, large exposures, or crypto assets, our understanding is that the total reported in row 0690 may still include other risk exposure amounts arising from non-credit risk categories, such as CCR (e.g. RWA induced by IMM PMA). Given that Row 1 of EU OV1 is intended to reflect credit risk excluding CCR, we would like to confirm whether including the residual amount from r0690 (after the above deductions) is appropriate, or if this could lead to misclassification of non-credit risk RWA under credit risk.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7524
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 21/08/2025

EBA Mapping Tool Clarification - EU MR3

Template EU MR3 - IMA values for trading portfolios (Row 4/8/12/16) According to the disclosure instruction (Annex XXX) & Article 455, MR3 will need to include related Internal Model Market Risk elements.  However, according to the EBA defined mapping for the above rows, which is mapped to C24.00, some IM elements (e.g. RNIME number) will be missed from the disclosure  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7513
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 21/08/2025

EBA Mapping Tool Clarification - EU OV1 & EU CMS1

With regards to the mapping logic used for EU OV1 & EU CMS1, in particularly for the Market Risk related rows, these currently reference the new FRTB related reporting templates with the C 90 series. As the implementation of FRTB is set to be delayed by a further year (refer to communication from the European Commission) until 1st January 2027, we believe that the mapping logic should be updated to reflect, referencing back to the pre-CRR3 Market Risk templates C18.00-C24.00, in addition to C02.00. In addition, we feel that in relation to EU OV1 template, the rows associated to Market Risk may require amendment to reflect the pre-CRR3 breakdown, unless the interim requirement is to mirror the approach to the of reporting (in C02.00), where data is reported under the Simplified standardised approach (S-SA) only.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7504
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 21/08/2025

EBA Mapping Tool Clarification - EU LIQ2

The EBA Mapping Tool logic in relation to EU LIQ2 does not appear to capture the 'Weighted Value' component. The current logic is as follows: {C 81.00, r0150, c0100} + {C 81.00, r0280, c0100}

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7496
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 21/08/2025

EBA Mapping Tool Clarification - EU CR5

For last Column aa – the mapping prescribed by EBA is ‘col z - {C 07.00, sum of rows [from 140 to 280], c 230, s0002}’ which means: •    Col z (i.e. sum of all the exposure value under different RW) •    C7:o    sum of rows [from 140 to 280] = sum of all RW% o    C230 in C7 = which ‘RISK WEIGHTED EXPOSURE AMOUNT OF WHICH:  WITH A CREDIT ASSESSMENT BY A NOMINATED ECAI’  Our question is why we use exposure value minus RWA with a ECAI assessment? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7488
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 21/08/2025

EBA Mapping Tool Clarification - EU CQ4

We believe that the mapping logic applied to EU CQ4 is incorrect for the following: For EU CQ4, r010, col a - Mapping is "'{F 20.04, sum(r0080, r0140), c0010} - {F20.04, sum(r0080, r0140), c0011}", however, F20.04, r010,r040, r0075 are excluded For EU CQ4, r010, col b - Mapping is "{F 20.04, sum(r0080, r0140), c0025}", however, F20.04, r010,r040, r0075 are excluded For EU CQ4, r010, col c - Mapping is "'{F 20.04, sum(r0080, r0140), c0026}", however, F20.04, r010,r040, r0075 are excluded For EU CQ4, r010, col d - Mapping is "{F 20.04, sum(r0080, r0140), c0012}", however, F20.04, r010,r040, r0075 are excluded For EU CQ4, r010, col e - Mapping is "{F 20.04, sum(r0080, r0140), c0031}", however, F20.04, r010,r040, r0075 are excluded For EU CQ4, r010, col g - Mapping is "{F 20.04, sum(r0080, r0140), c0040}", however, F20.04, r010,r040, r0075 are excluded

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7487
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 21/08/2025