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List of Q&A's

Amount to be reported as MREL eligible amount and amount qualifying as Own Funds non-CET1 instruments, taking into account phase-out as applicable

Could you please clarify whether in granular Resolution Plans reports (formerly SRB LDR) Z11.00, Z12.00, Z13.00 and Z14.00 the amount to be reported for Own Funds instruments (columns labelled Amount meeting the conditions for MREL eligibility ) and columns reporting on the Amount qualifying as Own Funds is: the carrying value + accrued interest as recommended for the measurement of non-CET1 instruments or the outstanding amount (outstanding principal + accrued interest) as mentioned for the Amount meeting the conditions for MREL eligibility?  For the columns reporting Own Funds there is no specific guidance on the amount type to be reported other than the amount of the instrument qualifying as Own Funds. 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on the provision of information for the purpose of resolution plans
  • ID: 2025_7614
  • Topic: Resolution plans
  • Date of submission:
  • Published as final Q&A: 03/04/2026

Reporting of unused prior permission amounts with no specification of subordination

How should banks report the unused prior permission amount in case the insolvency rank is not specified, and the unused prior permission amount exceeds the amount of eligible liabilities subordinated to excluded liabilities before the deduction of prior permission amounts (M02.00-r0100 to M02.00-r0130)? Furthermore, how should the unused prior permission amount be reported in cases where the subordinated layer only includes Tier 2 instruments, as T2 in phase-out is not covered by a general prior permission amount for eligible liabilities.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/763 – ITS with regard to the supervisory reporting and public disclosure of MREL
  • ID: 2025_7580
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 03/04/2026

COREP Additional Liquidity Monitoring Metrics - technical implementation of DPM v4.2 for template C_67.00.a and C_67.00.w - SubCategory "new_CO4" used instead of "new_CO1"

With DPM v4.2 the modeling of template C_67.00.a and C_67.00.w has been changed to use SubCategory new_CO4 instead of new_CO1. Now it is possible to submit the “LEI code”, the “MFI Code” and “Type of identifier, other than LEI or MFI code” but not the “National code”. How should a national code be reported in template C_67.00.a and C_67.00.w and what is the reason behind this change?

  • 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_7731
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 13/03/2026

Use of credit assessments by ECAIs not in scope of Regulation (EC) No 1060/2009.

Can external credit assessments that have been issued by an ECAI, but were not publicly disclosed, be used to determine the risk weight of an exposure under the Standardised Approach?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7220
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 13/03/2026

US Hard test: adequacy of considering US charge-off rates corresponding to loss rates for exposures secured by residential property or commercial immovable property situated within the territory of the US

May institutions in accordance with Article 199 (4a) of Regulation (EU) No 575/2013 (CRR) apply the derogations  from point (b) of paragraph 2 of Article 199 CRR, as referred to in paragraphs 3 and 4 of Article 199 CRR, for residential / commercial immovable property situated within the territory of the US, based on (adjusted) US charge-off rates as published by the Board of Governors of the Federal Reserve System (US), retrieved from FRED, Federal Reserve Bank of St. Louis? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7688
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 27/02/2026

Classification of phishing-attacks as a reportable major ICT-related incident

Can individual phishing incidents that target the customers of a financial entity in their “private sphere” be subsumed under “compromises the security of the network and information systems” pursuant to Article 3 No. 8 of Regulation (EU) 2022/2554 and can they therefore constitute a major ICT-related incident that must be reported pursuant to Article 19 (1) of Regulation (EU) 2022/2554? 

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/1772 - RTS on the classification of ICT-related incidents and cyber threats
  • ID: 2025_7613
  • Topic: ICT-related incidents (management / classification / reporting)
  • Date of submission:
  • Published as final Q&A: 06/02/2026

Types of "telephone services" included under the definition of "ICT services"

Which types of telephone services fall within the scope of the definition of "ICT services"? 

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7539
  • Topic: ICT-related incidents (management / classification / reporting)
  • Date of submission:
  • Published as final Q&A: 06/02/2026

Public Authorities Exemption

Is the exemption for public authorities as quoted in recital 63 sentence 3 last half-sentence meant to be a general exemption for all public authorities as defined under art. 3 no. 65 DORA when providing ICT related services in the context of fulfilling State functions, or is the exemption limited to payment services and payment-related solutions?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7466
  • Topic: Other DORA topics
  • Date of submission:
  • Published as final Q&A: 06/02/2026

Calculation of Ideosyncratic and Systematic Risk

In the COREP C25 on CVA, rows 0230 and 0240 demand the ideosycratic and systemic CVA risk. The scope that should be used for this calculation is not clear for us. Should the scope include the 'Memorandum' counterparties (e.g. not financial counterparties) or is this limited towards the 'Transactions in scope of own funds requirements' (e.g. financial counterparties)? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7483
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/01/2026

Threshold exemptions from deduction from Common Equity Tier 1 items – Reporting within CoRep C 07.00

Please can we clarify where exposure per article 48 (4), should be reported in COREP Template C 07, Row 0250. The underlying item of investment in question is an Equity investment arising from Trading book primarily assessed for Market Risk; to be more specific, the underlying are CET1 instruments which are in scope for Significant Holding per article 48 (1). Art. 133 is part of Standardised Approach to Credit Risk within Title II of the CRR where all Banking book investments are risk weighted by reading across 48(4) in line with 133(2). While Art. 48 is applicable for both Trading book and Banking book investments, the specific question is the applicability of Article 133(2) for a Trading book Equity Investment and therefore where should such items be reported in COREP C07 Template. EBA's Q&A referred to below is generic in nature.

  • 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)
  • ID: 2025_7473
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/01/2026

Setting limit (daily and/or per transaction) for the execution of payment transaction by PSP

Is PSP allowed, according to the Article 68(1) of PSD2, to set a general limit (daily and/or per transaction) for the execution of payment transaction to the payee with the PSP in another EU Member state, under the certain payment initiation channel (for example mobile banking), in order to mitigate the risk of fraud (to prevent fraud)? Is PSP allowed to set different general limits for national payments and for payments to PSPs in another EU Member state (due to various fraud risk associated to these transactions)? Is PSP obliged to change a limit above the limit that the PSP set - on PSU's request for regular credit transfer?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7425
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 12/12/2025

Definition of ‘demand deposits’ for FINREP reporting

How to report in FINREP loans and advances on demand and short notice that are not readily available at all times?

  • 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_7568
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 05/12/2025

Appropriate reporting of unconditionally cancellable commitments (UCCs) subject to transitional arrangements of Article 495d in CR SA (COREP C_07.00)

In the absence of specific guidance in the Annex, the scope of the new column c0195 Transitional arrangements for UCCs in C_07.00 and the expected reporting of such UCCs throughout the transition phase remains unclear. For example, the Bank has a UCC with a nominal value of €100,000, all of which remains undrawn over the transition period 1 January 2025 to 31 December 2032. Please confirm that the exposure shall be consistently reported as €100,000 in c0195 throughout the transition period 1 January 2025 to 31 December 2032, as follows.  Reference Period Transitional Arrangement Art 495d (1) Factor Example: UCC with nominal value of €100,000 Exposure Value     c0195 c0200 2025-2029 0% 100,000 0 2030 25% 100,000 2,500 2031 50% 100,000 5,000 2032 75% 100,000 7,500 Whilst acknowledging the relevant validations v6364_m and v0307_m, the proposed rationale is based on the principle that the UCC is in its entirety subject to the transitional arrangements as from the reference period 2025.  Effectively, this implies that c0195 shall consist of the fully adjusted exposure value prior to the application of both the CCF and the transitional factor laid down in Article 495d. Such reporting would also ensure alignment with c0150 and the preceding columns.

  • 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_7500
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 05/12/2025

C 25.01 - CREDIT VALUATION ADJUSTMENT RISK (CVA) – Col 0090 - Instruction Clarification

The CoRep instructions for the BA-CVA unhedged value point to CRR Article 384(3). The formula in this article contains the 0.65 discount factor.  However, as per the EBA’s Final Report on Amendments to the ITS on Supervisory Reporting - CRR3/CRD6, the EBA analysis column on question 18 (‘Q18’) mentions that the instructions for this column are clear that the discount factor of 0.65 shall not be applied. 

  • 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)
  • ID: 2025_7489
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 05/12/2025

Application of the SME definition in specific cases

How shall the SME definition in Article 5(9) of Regulation (EU) No 575/2013 (CRR) be applied in the following cases: 1. The entity is considered both in accounts on the consolidated basis of a group and also in accounts on a “sub-consolidated” basis only considering a sub-group of this group. 2. The entity is a single entity that prepares accounts on its individual basis but is not considered in any accounts for a “consolidated situation” of a group.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7512
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 28/11/2025

Definition and scope of ICT services

What is the correct reading of Article 3 (21) and Recital 63, Article 2 and Article 58(2) of Regulation (EU) No. (EU) 2022/2554 (DORA Reg) in combination with  the COM/2023/0365 European Commission Report on the review of Directive 2015/2366/EU ?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7290
  • Topic: ICT third-party risk management
  • Date of submission:
  • Published as final Q&A: 14/11/2025

Staff costs

Do imputed staff costs count as part of staff costs in accordance with Article 18(1)(f) of Regulation (EU) 2022/2554 in conjunction with Article 7(1)(c) Delegated Regulation (EU) 2024/1772 and Article 4(e) Delegated Regulation (EU) 2025/301 and must, therefore, be reported as part of gross direct and indirect costs and losses of an incident?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/1772 - RTS on the classification of ICT-related incidents and cyber threats
  • ID: 2025_7439
  • Topic: ICT-related incidents (management / classification / reporting)
  • Date of submission:
  • Published as final Q&A: 14/11/2025

Exposure to credit institutions in the form of derivative contracts

Should "exposure" also consider and include cash collateral held by the covered bond issuer from its swap counterparty? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7124
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as final Q&A: 07/11/2025

Calculation of the SME supporting factor for off-balance-sheet exposures

Is the SME supporting factor applicable, and if so, how shall it be computed, in case there is no on-balance-sheet exposure to be included in E*, as defined in Article 501(1) of CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7350
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 31/10/2025