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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

Validation rules taxonomy V4.0 C_10.00

The formulae of the control v23054_m seems irrelevant

  • 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: 2025_7446
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C_10.00

The formuale of the control seems irrelevant

  • 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: 2025_7447
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C_10.00

The formulae of the control seems irrelevant

  • 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: 2025_7448
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C_10.00

The formulae of the control seems irrelevant

  • 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: 2025_7449
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C_10.00

The formulae seems irrelevant

  • 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: 2025_7450
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C_08.01.a

Does the validation rule v23372_m should be applied to column 0250?

  • 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: 2025_7452
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Calculation of the Exposure-to-Value

How should be calculated the Exposure-to-Value (ETV) where a loan is secured by a combination of several liens on multiple properties (both residential and commercial) ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7247
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 03/06/2025

Risk weighting attributed to gold in the form of a commodity

Is the definition of “gold bullion”, as amended by Regulation (EU) 2024/1623, more restrictive than the definition previously set forth in the Regulation (EU) No 575/2013 (CRR), or this new definition shall be interpreted applying the clarification provided by the EBA in the Q&A 2016_3011?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7228
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 03/06/2025

Volatility Haircuts for Eligible Securitisation Collateral

Does the FCCM approach apply to unrated senior securitisation tranches that qualify as eligible collateral (i.e, as per article 197(1)h, "securitisation positions that are not resecuritisation positions and which are subject to a 100 % risk weight or lower in accordance with Article 261 to Article 264")?  If so, which supervisory volatility haircuts apply since there is no CQS associated with these under Sec- SA?  In addition, the new securtisation mappings of ECAI Ratings CQS 1-18 under Sec-ERBA have not been translated into Table 1 of Article 224, which continues to refer to CQS 1-4 seemingly under the old securitisation rules.  Which supervisory volatility haircuts apply under the new CQS mapping for rated securitisation tranches (as described in Commission Implementing Regulation (EU) 2016/1801 of 11 October 2016, as Amended by Commission Implementing Regulation (EU) 2022/2365 of 2 December 2022)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7214
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 03/06/2025

Calculation of minimum lease payments in case of operational lease

Does the EBA acknowledge that the residual value should be discounted, or the interests on this residual value should be filtered out of the calculation of the discounted minimum lease payments, to avoid an increase of the exposure beyond the accounting value?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7393
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 21/05/2025

Internal Model Method

What is the prudential treatment of cash flow spikes in the calculation of own funds requirements for counterparty credit risk under the Internal Model Method?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7303
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 21/05/2025

Clarification on Risk Weight Assignment for ADC Exposures in Default

Could you please clarify what risk weight should be applied to ADC exposures that are in default?

  • 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_7419
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 21/05/2025

Risk weighting attributed to gold in the form of a commodity

Is the definition of 'gold bullion', as recently amended by Regulation (EU) 2024/1623, consistent with the previous definition of 'gold' under Regulation (EU) No 575/2013 (CRR), as clarified by EBA Q&A 2016_3011, in the sense that it includes all forms of gold commodities (such as bars, ingots, jewels, manufactured products, and coins) whose value is determined exclusively by gold content—defined by purity and mass—regardless of their form, provided that no numismatic, artistic, branding, or other extrinsic value is attributed?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7423
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 01/05/2025

CCF of items (b) and (c) of bucket 5 from 2025 to 2032

Which credit conversion factor shall be applied to the undrawn amount of retail credit lines for which the terms permit the institution to cancel them to the full extent allowable under consumer protection and related legal acts (item listed in point (b) of bucket 5), and to undrawn credit facilities for tender and performance guarantees which may be cancelled unconditionally at any time without prior notice, or that do effectively provide for automatic cancellation due to deterioration in a borrower’s creditworthiness (item listed in point (c) of bucket 5) in the years 2025 to 2032?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7318
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 23/04/2025

Financial Sector Entity qualification for entity that assumes a loan in order to acquire an aircraft asset which then enters into a financial leasing agreement with an airline / aircraft operator

Should an entity that assumes a loan in order to acquire an aircraft asset which then enters into a financial leasing agreement with an airline / aircraft operator be treated as object finance / specialised lending or does it in addition need to be viewed as an exposure to a financial institution (and therefore a financial sector entity (FSE)) given the entity enters into a finance leasing arrangement that is an activity set out in point 3 of Annex I of Directive 2013/36/EU?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7120
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 28/03/2025

Treatment of leasing residual values under the standardized approach for credit risk

May the ‘’1/t*100%* residual value” formula introduced by CRR article 134.7 for the risk-weighted exposure amounts be applied to all leasing residual values? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7195
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 27/03/2025

EBA publication on hard test results

Does EBA plan to publish information related to loss rates for immovable property markets in third countries? If yes, when is such a publication to be expected and which third countries will be covered?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7197
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 27/03/2025

Can the Article 122a adjustment be combined with the Article 501 SME-adjustment?

The Article 122a paragraph 3  letter c subletter ii CRR says, that if all the criteria are met, there can be a factor of 80 % applied. But it can't be combined with the 75 % adjustment of Artikle 501a. But can it be combined with the adjustment for SMEs due to Article 501?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7186
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 19/03/2025

Remaining maturity of the transactions for collateralised transactions

As per CRR Article 162(2)(c)& (d)- This states (as per below). Can the term "remaining maturity" in the below paragraphs be defined as Margin Period of Risk for collateralised transactions and Contractual maturity for un-collateralised transactions? (c)  for exposures arising from fully or nearly-fully collateralised derivative instruments listed in Annex II and fully or nearly-fully collateralised margin lending transactions which are subject to a master netting agreement, M shall be the weighted average remaining maturity of the transactions where M shall be at least 10 days; (d)  for repurchase transactions or securities or commodities lending or borrowing transactions which are subject to a master netting agreement, M shall be the weighted average remaining maturity of the transactions where M shall be at least five days. The notional amount of each transaction shall be used for weighting the maturity;

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/11 - Guidelines on disclosure requirements under Part Eight of CRR
  • ID: 2024_7204
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 07/03/2025