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List of Q&A's

Encumbrance reporting treatment of surplus assets in a cover pool

Can surplus assets within a covered bond pool that are economically available to the issuer and above minimum over-collateralisation requirements (regulatory, contractual and what is required by the rating agencies to maintain the rating) be reported as unencumbered where they are subject only to an operational process for withdrawal?

  • 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_7696
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

Incoherent formulae on the control v10667_m

Could you please confirm that items that should be compared are the result of multiplying row by row each c0250 of CR IRB 2 (C08.02) by c0110 of CR IRB 2, and the result of multiplying r0070/c0250 of CR IRB 1 by the sum of c0110 of CR IRB 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_7791
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

Incoherent formulae on the validation rule v23089_m

Could you please confirm that the formulae of the control v23089_m needs to be modified ?

  • 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_7794
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

Incoherent formulae on the validation rule v0470_m

Is the validation rule v0470_m coherent?

  • 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_7849
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

Incoherent formulae of the validation rule v903627_h

Could you please therefore confirm that the validation rule should be inactive?

  • 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_7856
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

Incoherent formulae of the validation rule v22949_m

Is the formulae of the validation rule v22949_m coherent?

  • 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_7863
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

Validation rules taxonomy V4.2 C09.02 v903627_h

In the latest set of EBA validations rules, VR v903627_h has been added effective 31/03/2026. This validation rule is identical to the earlier deactivated v23650_h. Via 2025_7323 it was earlier raised that v23650_h is not correct. Hence, we feel that the same applies to v903627_h. 

  • 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_7864
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

Validity of validation rule v10667

Validation rule v10667 seems invalid. with {default: 0, interval: true}:      sum(          {tC_08.01.a, r0070, c0250}          [where qEEA in {              [eba_qAE:qx2013], [eba_qAE:qx2015], [eba_qAE:qx2021], [eba_qAE:qx2071],              [eba_qAE:qx2073], [eba_qAE:qx2075], [eba_qAE:qx2022], [eba_qAE:qx2012],              [eba_qAE:qx2014], [eba_qAE:qx2018], [eba_qAE:qx2020], [eba_qAE:qx2072],              [eba_qAE:qx2074], [eba_qAE:qx2076]          }]      )      *      sum(          {tC_08.02, c0110}          [where qEEA in {              [eba_qAE:qx2013], [eba_qAE:qx2015], [eba_qAE:qx2021], [eba_qAE:qx2071],              [eba_qAE:qx2073], [eba_qAE:qx2075], [eba_qAE:qx2022], [eba_qAE:qx2012],              [eba_qAE:qx2014], [eba_qAE:qx2018], [eba_qAE:qx2020], [eba_qAE:qx2072],              [eba_qAE:qx2074], [eba_qAE:qx2076]          }]      )      =      sum(          {tC_08.02, c0250}          [where qEEA in {              [eba_qAE:qx2013], [eba_qAE:qx2015], [eba_qAE:qx2021], [eba_qAE:qx2071],              [eba_qAE:qx2073], [eba_qAE:qx2075], [eba_qAE:qx2022], [eba_qAE:qx2012],              [eba_qAE:qx2014], [eba_qAE:qx2018], [eba_qAE:qx2020], [eba_qAE:qx2072],              [eba_qAE:qx2074], [eba_qAE:qx2076]          }]      )      *      sum(          {tC_08.02, c0110}          [where qEEA in {              [eba_qAE:qx2013], [eba_qAE:qx2015], [eba_qAE:qx2021], [eba_qAE:qx2071],              [eba_qAE:qx2073], [eba_qAE:qx2075], [eba_qAE:qx2022], [eba_qAE:qx2012],              [eba_qAE:qx2014], [eba_qAE:qx2018], [eba_qAE:qx2020], [eba_qAE:qx2072],              [eba_qAE:qx2074], [eba_qAE:qx2076]          }]      ) We have encountered an error on this check which seems to be caused by the accuracy of the metric involved. c0250 in C08.01 and C08.02 is requested as a whole number. This causes rounding to be applied at the global (across obligor grades) level for C08.01, but at the level of C08.02 the rounding is done per obligor grade. This introduces differences between the results of the left and right side of the validation rule.  

  • 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_7872
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

EBA validation v23089_m does not allow values

EBA validation v23089_m states: with {tC_10.00, (r0010, r0020, r0040, r0050, r0060, r0070, r0080, r0090, r0100, r0101, r0110, r0120, r0130, r0131, r0132, r0150, r0151, r0152, r0153, r0154, r0155, r0156, r0157, r0158, r0159, r0160, r0161, r0162, r0163, r0170, r0230, r0240, r0250, r0260), default: null, interval: false}: isnull({c0120}) The validation only allows values in rows r0180, r0190, r0200, r0210, r0220, r0230 and r0270, while CRR IRB-IMM exposures, calculated based on SA, can be split over many exposure classes (r0040 to r0240). However this validation rule does not allow amounts to be reported in r0040-r0240 in c0120. We believe this is a mistake.

  • 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_7873
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

C09.02 - EBA VR v903627_h

The EBA Validation Rule v903627_h applicable to the C09.02 template states that the row 0030 (Corporates) shall be equal to row 0050 (Of which: SME) plus the row 0051 (Of which: Large Corporates) for almost all the columns of the template.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7875
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

C08.01 - EBA VR v10667_m

The EBA Validation Rule v10667_m applicable to the templates C.08.01 and C.08.02 COREP templates states that the Exposure-weighted average maturity value (days) of C.08.01 (column 250) of the row 70 (Exposures assigned to obligor grades or pools) multiplied by the total of the column 110 of C.08.02 (Exposure value) must be equal to the sum of the Exposure-weighted average maturity value (days) of C.08.02 (column 250) multiplied by the sum of the Exposure value of C.08.02 (column 110).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7881
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

C08.01 - EBA VR v4757_m

The EBA Validation Rule v4757_m applicable to the C08.01 template states that the column c0280 (Expected loss) shall be lower or equal to the column 0020 (Gross exposure).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7882
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

Validation Rule v22950_m – warning generated for exposure class [eba_qEC:qx2038] in C 07.00a

Validation rule v22950_m requires that cells in C 07.00a, row 0062 are blank for exposure class [eba_qEC:qx2038] – “Exposures secured by mortgages on immovable property and ADC”. However, the instructions for row 0062 state: “of which: IPRE exposures where the derogation set out in Article 125(2) of Regulation (EU) No 575/2013, second subparagraph is applied. Only reported in sub-exposure class ‘Secured by mortgages on residential immovable property – IPRE’.” According to the DPM hierarchy, qx2038 is the parent exposure class of – ‘Secured by mortgages on residential immovable property – IPRE’. As amounts reported are reflected in the corresponding parent exposure class, the inclusion of qx2038 in validation rule v22950_m generates a warning despite the reporting being consistent with the instructions.  Rule Reference: isnull ({tC_07.00.a, r0062, (c0010, c0030, c0040, c0150, c0160, c0165, c0170, c0175, c0180, c0190, c0195, c0200, c0215, c0220), default: null, interval: false} [ where qEBB in {[eba_qEC:qx16], [eba_qEC:qx23], [eba_qEC:qx22], [eba_qEC:qx21], [eba_qEC:qx20], [eba_qEC:qx19], [eba_qEC:qx2043], [eba_qEC:qx2036], [eba_qEC:qx2060], [eba_qEC:qx2037], [eba_qEC:qx2061], [eba_qEC:qx2063], [eba_qEC:qx2049], [eba_qEC:qx12], [eba_qEC:qx2050], [eba_qEC:qx13], [eba_qEC:qx18], [eba_qEC:qx14], [eba_qEC:qx1], [eba_qEC:qx25], [eba_qEC:qx26], [eba_qEC:qx2038], [eba_qEC:qx2039], [eba_qEC:qx2040], [eba_qEC:qx2041]}]) 

  • 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_7946
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

The control formula v11889_m lacks sufficient evidential value.

Only the Total sheet  ([eba_qAE:qx2023]) must be empty for column 0070 (LGD).  Should control over another sheet (other than [eba_qAE:qx2023]) really exist ? Should it not be deleted ?

  • 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_7952
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

The control formula v10666_m lacks sufficient evidential value.

The control rule in place is incompatible with the EBA Filing Rules - section 2.18 on decimal precision requirements. Could these rules be amended?

  • 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_7950
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

The control formula v11888_m lacks sufficient evidential value.

Only the Total sheet  ([eba_qAE:qx2023]) must be empty for column 0050 (PD).  Should control over another sheet (other than [eba_qAE:qx2023]) really exist ? Should it not be deleted ?

  • 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_7951
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

Treatment of a guarantee provided by a supranational institution on a securitisation tranche for RWA calculation purposes

How should an institution reflect, for own funds requirements purposes, an external guarantee provided by a supranational institution (such as the EIF, European Investment Fund) on a securitisation tranche?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7842
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

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