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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

ESG P3 - Template 2 and 5 - Gross carrying amount for loans collateralized by RRE/CRE and multiple collaterals

Question 1: For loans collateralised by CRE and/or RRE, to be reported in template 2 & 5, does the regulation allow to have their gross carrying amount not matching the gross carrying amount of the same loans reported in FINREP? Question 2: Does Q&A 6517 apply for both template 2 and 5 or only for template 5?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

COREP v3.2 – C 33.00

Regulation (EU) 2022/1994 amending the implementing technical standards laid on in Implementing Regulation (EU) 2021/451 changes the direction of the 2nd parenthesis for the period intervals of rows 0170 to 0230, which generates a 'double counting', example below: r0170 [0 – 3M] r0180 [3M – 1Y] r0190 [1Y – 2Y] r0200 [2Y – 3Y] r0210 [3Y – 5Y] r0220 [5Y – 10Y] r0230 [10Y – more] The periods 3M, 1Y, 2Y, 3Y, 5Y and 10Y would be declared on 2 rows each time.

  • 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

Deferred Tax Liabilities (DTL) that are non-deductible from Deferred tax assets (DTA) as per accounting rule

Where do we book the temporary Deferred Tax Liabilities(DTL) differences that are non deductible from Deferred tax assets (DTA) as per accounting rule?

  • 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

Securitised derecognised assets

Template C 14.00 (SEC DETAILS), column 0210, requires reporting of information on securitised exposures including associated provisions. The memorandum item on the standardised calculation in C 14.01 (SEC DETAILS APPROACH), column 0448 also requires provisions on underlying asset as an input. What provisions should be used when the securitised exposures are also derecognised by the reporting entity from an accounting perspective?

  • 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

Calculation of RWA for assets that are deducted from own funds

As a follow-up question to Q&A 6106, what would be the appropriate risk weight to be used for the purposes of col 0030 'RWEAs: SA exposures' in the case of assets that are deducted from own funds?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)

Transfers to PPE

We have a collateral obtained some years back that was classified as Commercial Immovable property. In the current year the Group decided to transfer this property to PPE and use it for its own branches.  In table 25.1 the below rows exist. Where can we put the transfer (therefore outflow) mentioned above? Outflow for which cash was collected Outflow with replacement by financial instrument Outflow due to negative changes in value

  • 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

Bucket definition (PD range) in the ITS on supervisory reporting

Does Q&A 6718 also modify the definition of the row 'PD Range'?

  • 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

Should collateral received via securities financing transaction that is subsequently sold short be reported as encumbered in F32.02? Follow-up question on 2014_946 related to short positions in Asset Encumbrance

As clarified in Q&A 946 “Selling collateral received (short sale) does not give rise to encumbrance”. Two scenarios are addressed under this Q&A and further clarity is sought on scenario one and the reporting of collateral received in template F 32.02 where such collateral is subsequently sold short. Is it the intended view that within F 32.02 where an institution receives collateral, against cash, and then uses that collateral received to cover a short position, that the received collateral should be reported as unencumbered in F 32.02, column 040?  If so, can you please provide supporting rationale that selling collateral received (short sale) does not give rise to encumbrance given that once the collateral is sold short, it is not available for re-use by the institution?

  • 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

Clarification of scope of population for Corporate Bonds

In accordance with the instructions for row 0060 of template C 34.08 in Annex II of Commission Implementing Regulation (EU) 2021/451, there is no specific definition of what the scope of corporate bonds should include. Could you, therefore, please confirm if this should include all bonds issued by Institutions and Corporate entities and if it would also include securitisation bonds issued by these entities as well or not or, alternatively, would only non-securitisation instruments issued by entities which would qualify for the corporates credit risk exposure class under Article 112(g) of the CRR be included? We would also request clarification on securitisation bonds, whether those issued by government agencies e.g., Fannie Mae should be reported in row 0050.

  • 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

COREP Large exposure, validation rule v_1678 related to POCI assets

In case of purchased or originated credit-impaired financial assets (POCI), it is possible that the value for positive 'value adjustments and provisions' exceeds the 'value of total original exposure' can be reported in COREP Large reports. However, DPM validation rule v_1678_m does not allow reporting of such cases.  Since it is possible to have positive impairments that exceed the total original exposure for the POCI assets, could the validation rule or its severity be modified in this respect?

  • 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

Trusted Beneficiaries

Please clarify whether under Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication (hereinafter: RTS on SCA & CSC) is it allowed to use the same SCA element to authorize a payment and at the same time (using the same session ID) approve (technically using by a checkbox) the payee as a trusted beneficiary? If it is allowed, the payment service user (hereinafter: PSU) shall be informed (prior to authorisation) by an approval SCA element (SMS) about the payment execution and about modifying the list of the trusted beneficiaries as well?

  • 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

Exemption from strong customer authentication

Do the revisions to Art.10 set out in Commission Delegated Regulation (EU) 2022/2360 of 3 August 2022 amending the regulatory technical standards laid down in Delegated Regulation (EU) 2018/389 as regards the 90-day exemption for account access mean that a payment service user or account information service provider is now limited to accessing only the account balance OR the transaction details for the last 90 days when availing of the revised exemption?

  • 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

App to app redirection with biometrics for PIS

Are ASPSPs required to offer redirected authentication with biometrics to users accessing their payment accounts through an AISP or initiating a payment through a PISP, if they offer redirected authentication with biometrics to users accessing accounts or initiating payments directly via the ASPSP?

  • 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

Service Downtime

The question refers to the case that an incident with a duration of two hours that disrupts transaction processing occurs around the daily cut off time of same-day transactions processing. Thus, the incident may be of a short duration, but as a result, transactions are booked one day later. Considering this example, what service downtime should the payment service provider (PSP) indicate in the PSD2 notification? Just the net time of the failure or the total time any payment service users are affected by delayed transactions, i.e. one day?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/03 - Guidelines on major incident reporting under PSD2 - repealing EBA/GL/2017/10

Period to be covered by statistics pursuant to Article 32(4) of Commission Delegated Regulation (EU) 2018/389

Which period should the statistics to be published by ASPSPs under Article 32(4) of Commission Delegated Regulation (EU) 2018/389 cover in total?

  • 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

Evidences / Records to be stored by account servicing payment service providers (ASPSP) for payment initiation service (PIS) and account information service (AIS) requests

Shall ASPSP keep record of PIS requests received through a PISP and evidences on the authenticity and execution of these payment transactions when SCA is managed by ASPSP ?  Shall ASPSP keep record of the consent of the PSU and also of the AIS requests received through an AISP ? For both evidences is there any specific retention period ?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Reading of the term "means of payment"

What are the 'means of payment' in the LNE Guidelines (guidelines 1.6 and 1.7)? Does the term refer to the technological level of a physical device or a digital carrier, which may accommodate several payment instruments, such as plastic card (chip or magnetic stripe), a mobile phone, a wallet, an app, a wearable, a tablet, a PC or even a specific storage location on an external server? Please provide examples of 'other means of payment' that are relevant in practice from the EBA's perspective. How is the definition of payment instrument according to Article 4(14) PSD2 to be read in the context of the LNE Guidelines? Is the interpretation of the adjective “card-based” (in combination with means of payment) in line with the same adjective in combination with payment instruments according to Article 2(20) of Regulation (EU) 2015/751 (“IFR”)?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2022/02 - Guidelines on the limited network exclusion

C43.00 (LR4) – Reporting of RWA for positions in CIUs

What value for RWA shall institutions report for positions in CIU considering that the look-through approach shall not be used for Leverage Ratio purposes?

  • 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

Permission to reduce own funds or eligible liabilities and deduction rules in the context of a liability management exercise (exchange offer, tender offer or issuance of a replacement instrument concurrent with a tender offer on the existing instrument)

Should deductions from own funds and eligible liabilities with regards to a permission to reduce own funds or eligible liabilities in accordance with Article 77 of Regulation (EU) No 575/2013 (CRR) in the context of a liability management exercise (exchange offer, tender offer or issuance of a replacement instrument concurrent with a tender offer on the existing instrument), rather than upon the exercise of a call option,  be made right after the permission from the competent authority / resolution authority is granted or could it be later at the time of the institution’s public announcement of the liability management exercise in accordance with Article 28(2) of the RTS on Own Funds? In that context, how should the concept of ‘sufficient certainty’ of Article 28(2) RTS be applied?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions