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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

Paper-based postal money orders as defined by the Universal Postal Union

1. Should postal transfers as defined by the Universal Postal Union, which are not made in paper form but by electronic means, be excluded from the scope of PSD2?     2. If postal transfers, as defined by the Universal Postal Union, in both electronic and paper format, are inseparable from the postal operator’s accounting system, should also paper-based postal transfers not fall outside the scope of PSD2?     3. Should such transfers be excluded from the scope of PSD2 in either case, or agree that the payment institution is not entitled to credit those funds to the payment service customers’ funds accounts where the money of the payment service users is kept separate?     4. Can a payment institution that is also a postal service provider simultaneously provide both PSD2 regulated services and services related to payments but outside the scope of PSD2?

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

Eligibility of funded credit protection received from third parties

Can cash collateral received from third parties via funded credit protection arrangements (i.e. funded guarantees or credit derivatives) qualify as collateral for the purposes of K-TCD and K-CON? 

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Net position risk - K-NPR

We understand that rTM measures are for firms that deal on their own account. The relevant K-Factor for position risk, K-NPR falls under rTM, therefore the assumption would be that K-NPR refers only to firms dealing on their own account. However, Article 21(4) sets out that for purpose of calculating the rTM K-factor requirement, firms should also include positions other than trading book positions where it gives rise to foreign exchange or commodity risk.  Does then Article 21(4)  bring firms that do not deal on their own account into the scope of K-NPR or is it an additional requirement only for firms that deal on their own account?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Applying risk weight in accordance with Article 235(3) of CRR3

In case of exposure and guarantee denominated in different currencies, which currency shall be taken into account in the process of application of risk weight for guaranteed part of exposure in accordance with Article 235(3) of CRR3?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Scope of Subordinated Debt Exposures under Art. 128 (1)(c)

Which bonds can be considered "subordinated debt" under Art. 128 (c)? Only senior non-preferred bonds? Senior Non-Preferred Bonds and Senior Preferred Bonds (which meet the criteria under Art. 72b(3)? Senior Non-Preferred Bonds and Senior Preferred Bonds (that meet the criteria set out in Art. 72b(3) and are recognized as eligible liabilities by the resolution authority)? Senior Non-Preferred Bonds and Senior Preferred Bonds issued by G-SII entities (which meet the criteria set out in Art. 72b(3) and are recognised by the resolution authority as eligible liabilities)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

C 25.01 - CREDIT VALUATION ADJUSTMENT RISK (CVA) - Template Dimensions - Row 0130 / Column 0050

C 25.01 Data point intersecting Row 0130 (“Total non-centrally cleared SFTs that are fair-valued for accounting purposes, excluding exempted transactions” and Column 0050 (“Simplified treatment for derivative positions of CIU”) – we do not believe that the template dimensions are correct whereby SFTs are subset of derivatives.

  • 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)

Multilateral development banks classification for the purpose of article 325ah

Buckets 2 and 11 of Table 4 in Article 325ah refer to the category of multilateral development banks (MDBs) and international organisations (IORGs) referred to in Article 117(2) or Article 118 of CRR. At the same time, paragraph 2 of the same article 325ah, requires the use of a classification that is commonly used in the market for grouping issuers by sector, in order to assign a risk exposure to a sector.  Assuming that such a market wide accepted classification would show a certain counterparty as an MDB, as long as this specific counterparty is not listed in the above listed articles mentioned for buckets 2 and 11 of Table 4 in Article 325ah (as a one to one match) , then this counterparty would need to be assigned to a different bucket, likely 4 or 13.  Can there be a departure from the specific list of MDBs and IORGs, as referred to in Article 117(2) or Article 118 of CRR, for the purpose of Table 4 in Article 325ah of CRR? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Collateral requirements for the ‚another credit protection‘ alternative in the form of cash on deposit held with a third-party credit institution

Does Article 26e (10) (b) of the Amended Securitisation Regulation allow cash collateral to be provided also in the form of a guarantee or letter of credit given by a qualifying third-party credit institution?

  • Legal act: Regulation (EU) No 2017/2402 (SecReg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Retained covered bonds not used for funding – F35.00

Should retained/own covered bonds that do not generate liabilities on the bank's balance sheet be reported in the Covered bond liabilities columns 0020-0140?

  • 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 (repealed)

C 02.00 - OWN FUNDS REQUIREMENTS (CA2) - CoRep S-TREA Allocation in Col 0020

C 02.00 – Row 690/ Col 0020 (Other RWA under S-TREA): If the firm were back testing any models that identified a shortfall, would this necessarily result in the equivalent Fully Standardised RWA needing to be computed, given that the fully standardised position would be driven by rule-based criteria, so in essence captured in the appropriate rows before Row 690 (risk types) already? In addition, for any regulator driven add-ons, again assume the same would 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)

DPM 4.0 - Correctness of identical cells for C 08.01.c

For DPM 4.0 the cells {C_08.01.c, r0070, c0130, s*} and {C_08.01.c, r0180, c0130, s*} are identified as identical and have the same VariableID. Considering the instructions for reporting the data in rows 0070 and 0180 different values are expected.

  • 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

XBRL Modelisation of FICOD REPORTING L0600

In the report C0700 we saw that the new dynamism with the errata 5 is using the value qEC:qx1 to display the “total” breakdown and for us it seems to be fine qEC2 20392 4.0   1012404739 qx01 All exposure classes and approaches   Where in report C080* and C3407, we understand that the taxonomy is allowing three types of totals : => (In the table below qae0 is used on report C0801,C0802, C08.03,C0805, C0805.1 , where aAE0 is used for report C3407) SubCategoryCode SubCategoryVID StartReleaseCode EndReleaseCode ItemID ItemCode ItemName qAE0 20379 4.0   1012404873 qx2022 Total without own estimates of LGD or conversion factors qAE0 20379 4.0   1012404874 qx2023 Total with own estimates of LGD and/or conversion factors qAE0 20379 4.0   1012407843 qx01 All exposure classes and approaches qAE1 20380 4.0   1012404873 qx2022 Total without own estimates of LGD or conversion factors qAE1 20380 4.0   1012404874 qx2023 Total with own estimates of LGD and/or conversion factors qAE1 20380 4.0   1012407843 qx01 All exposure classes and approaches   From my point of view when I look at the ITS and more specifically to the ITS relative to the report C08* exposure classes, I only see that the report should have a : Dedicated sheet for A.1 Total under the “IRB approaches when neither own estimates of LGD nor Conversion Factors are used (Foundation IRB approach)” section for me this correspond to qx2022 Dedicated sheet for B.1 Total under the “IRB approaches when own estimates of LGD and/or Conversion Factors are used” section for me this correspond to qx2023 But I do not see a need for a dedicated sheet corresponding to an overall TOTAL as it should be for “qx0 : Not applicable/ All exposure classes and approaches”    Furthermore when I look at the validation I saw that some of them that works on the TOTAL exposures like : v0680_m  : with {default: 0, interval: true}: sum ({tC_43.00.a, r0040, c0020}) = sum ({tC_07.00.a, r0130, c0220} [ where qEBB in {[eba_qEC:qx0]}]) + sum ({tC_08.01.a, r0060, c0260} [ where qEEA in {[eba_qAE:qx2022], [eba_qAE:qx2023]}])   We see that for report C0700 the value eba_qEC:qx0 (now this value correspond to value qx1 since the errata 5 of the taxonomy) is used where for report C0801 only the values eba_qAE:qx2022, eba_qAE:qx2023 are used.   Can you indicate If the EBA is expecting the filler to fill up the dynamism on dimension eba_qAE:qx1 for report C080* / C3407or if we can tell our client to not use this value?   

  • 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

Reporting of the Application of Article 465(5) of CRR in template C 10.00

Could EBA provide guidance on whether institutions that do not apply the transitional arrangements set out in Article 465(5) of CRR can leave the rows 0151 and 0152 ‘of which: exposures secured by mortgages on residential property up to 55% of the property value’ and ‘of which: exposures secured by mortgages on residential property between the 55% and 80% of the property value’ empty in template C 10.00?  

  • 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

Reporting aggregate exposure to shadow banking entities in CRR3

The newly introduced paragraph 2(b) in article 394 of CRR3 requires institutions to report as well the total Shadow Bank Exposure. This request is in addition to the top 10 such SBEs, already reported under CRR2, in line with paragraph 2(a) of the same article. Nonetheless the new ITS published under taxonomy v4.0, do not include any field which would allow us to report such information.   

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Clarification of reporting of lending or financing where the use of proceeds is unknown in row 440 from Template 7 (ESG Disclosure)

Should all the instruments or lending against Sovereigns, where the use of proceeds is unknown, be excluded from the numerator of Template 7 ESG Disclosure - row 460 - Sovereigns and moved to row 440 - Other assets (e.g. Goodwill, commodities etc.)?

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

C_25.01.b Datapoint Modelling

The datapoint modeling for C_25.01.b does not align for rows 10 & 20 with that of C_25.01.a. The datapoint model for C_25.01.a lists (qAFF:qFI) Type of Financial Instruments while C_25.01.b does not. 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Application of recognised SyRB on a consolidated basis

May or shall a competent or a designated authority from a Member State, that recognises a systemic risk buffer rate set by another Member State in accordance with Article 133 of the CRD, require its domestically authorised institutions to apply that rate on a consolidated basis, covering all exposures targeted by the recognised systemic risk buffer held through subsidiaries, branches or through cross-border lending, in accordance with Article 134 of the CRD ? Does the legal framework permit or require that exposures of domestically authorised institutions held through subsidiaries located in the Member State that sets the buffer rate as well as in other Member States are also included in the scope of recognition? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Compliance of non-bank PSPs with the safeguarding requirements in PSD2

Where PIs and EMIs (referred to as non-bank PSPs) have direct access to central bank operated payment systems for settling payment transactions, would keeping a balance on a settlement account with the central bank/payment system, without the central bank maintaining a safeguarding account for the non-bank PSP, be compliant with the safeguarding requirements under Article 10 of PSD2?

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

Counterparty classification

On FINREP reports, each counterparty is classified into a counterparty type, like Household or Government. Some government services are provided by volunteers, which raises the question how this should be classified, since the people are technically not employed by the government. Examples include volunteer police or volunteer firefighters and their unions, whose members provide and/or facilitate services specific to governments.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Scaling of gross JTD amounts of securitisation tranches with a maturity less than one year

Should the tranche maturity (MT) of less than one year of gross JTD amounts of securitisation tranches resulting from either formula in Art. 257(1) CRR be floored at one year as required by para. 2 of this Article, or can the MT be used without this floor of one year in order to enable scaling, with a floor of three months, as prescribed by Art. 325z(5) CRR in conjunction with Art. 325x(3) CRR? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable