Search for Q&As

Enquirers can use various factors to search for a Q&A:

  • These include searching by the Q&A ID; legal reference, date submitted, technical standard / guideline, or by keyword if known.
  • Searches can be extended to more than one legal act, topic, technical standard or guidelines by making multiple selections (i.e. pressing 'Ctrl' on your keyboard, and selecting the relevant ones from the drop-down lists by left mouse-click).

Note for users:

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. You should therefore check the date of publication and whether the provisions referred to in the final Q&As remain the same.

An overview of all the Q&As affected by the review of CRR-CRD and BRRD Q&As against the revised versions of those legislative acts following the amendments introduced in June 2019 can be accessed here (updated on 10.12.2021).

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

F 31.01 in combination with Q&A 915

According to Q&A_915 and EBA-ITS v3.0, the EBA considers validation rule 1034_m still as accurate. We're seeking a clarification whether EBA also has taken into account IAS 24.26 when answering in 2014.

  • 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

Inclusion of certain AVA categories into the Total AVA in C 32.02

Should the AVA categories of column 0070 ('Concentrated positions'), column 0080 ('Future administrative costs'), column 0090 ('Early termination') and column 0100 ('Operational risk') of C 32.02 be incorporated into what is reported in template C 32.02, column 0110 ('Total AVA')?

  • 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

Adding to own funds the unredeemed part of own funds.

When and under what conditions can the unredeemed part of own funds, for the redemption of which an institution had previously obtained a general prior permission from the competent authority in accordance with Article 77 and the second subparagraph of Article 78(1) of Regulation (EU) No 575/2013 (CRR), be included in own funds again?

  • 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

Reporting of physically settled derivatives in C 66.01 Maturity ladder

  In which sheet should we report the commodity flows in the C 66.01 Counterbalancing section - only in the TOTAL sheet (for all currencies combined) or also in the corresponding significant currency sheet? Does reporting depend on the type of commodity - metals, energy, agriculture, etc.? 

  • 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

v09808_m - netting set with IMM and SA-CCR positions

In template C 34.02, the columns current market value (CMV), positive (c0040) and Current market value (CMV), negative (c0050) are to be presented as a sum of the current market values (CMV) of all the netting sets. In order to comply with requirements, the CMVs are to be presented on netting set level. Split between positive and negative CMV presented in columns 0040 and 0050 respectively is done on the netting sets level, however netting set may comprise both SA-CCR and IMM derivatives. An ISDA agreement can cover derivatives that can be either calculated using the IMM or SA-CCR, i.e. a single netting set can be presented in both rows 0030 and 0040. Are the following assumptions correct? In order to comply with the template logic, such a netting set would be split to IMM and SA-CCR parts and CMV will be then calculated for respective splits. Those splits can result in opposite signs. However, as the definition of the template says the CMV shall be calculated on a netting set, the total will be always present only as strictly positive or strictly negative. Then in C34.02 template, total value of the netting sets with positive and negative CMV will reconcile with the total positive and negative CMV of presented approaches (sum of columns 0040 and 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

How shall open maturity repos be reported in C 81.00 and with which ASF factor ?

It is not totally clear what the term 'unless otherwise specified' in Article 428k of Regulation (EU) No 575/2013 CRR, as amended by Regulation (EU) 2019/876, means for an open repo. Does the use of the term 'unless otherwise specified' in the sentence 'unless otherwise specified in Articles 428l to 428o, all liabilities without a stated maturity, including short positions and open maturity positions, shall be subject to a 0 % available stable funding factor' mean that an ASF factor corresponding to the type of counterparty must be applied as per the article 428l to 428o CRR first?  One answer is to allocate to the open maturity repo an ASF factor based on the counterparty as for the other kind of liabilities, thus 50% for non financial counterparties and 0% else, considering the open maturity repos are in the first bucket 0-6 months. An alternative is that articles 428l to 428o CRR are only valid for deals with a maturity and thus the ASF factor should be 0% whatever the type of counterparty.  About the reporting C 81.00, in the first case, the proposal is to report the open repo with other liabilities of the same counterparty type, thus potentially in section 2.3 for non-financial customers or section 2.5 for financial ones to keep coherence on the ASF factors. For the alternative, the open repos must be reported in 2.9.4 as specified in the ITS. 

  • 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

Amount of certain CET1 items available for stable funding

For the purposes of calculating available stable funding, it is unclear what amount should be reported, if any, as regards the following CET1 items: a) retained earnings, b) minority interests and c) amounts added back to CET1 due to the application of IFRS 9 transitional arrangements (Article 473a CRR).

  • 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

ITS ESG P3 - Template 4 - Top 20 emitting companies aggregation

Should reported exposures to top 20 most emitting companies be reported at a group or individual company level?

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

Inconsistencies between FINREP (F 02.00) and Funding Plans (P 04.01)

Will validation rule v08928_m be deactivated, temporarily? Where shall 'Cash contributions to resolution funds and deposit guarantee schemes' be included until row r0385 will be introduced in P 04.01?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2019/05 – Guidelines on harmonised definitions and templates for funding plans of credit institutions under Recommendation A4 of ESRB/2012/2 - repealing EBA/GL/2014/04

C 48.02: doubts about ‘daily reporting’: how the amount referred to no business day has to be reported?

I have some doubts about the ‘daily reporting’ in the template C 48.02 as the regulation changed from ‘business days’ to ‘each day of the reporting period’. I would like to know how the amount referred to no business day has to be reported: Banks have to drag the amount of the previous day (for example if the reporting day is Saturday and the bank has not operativity the reporting bank has to drag the amount of Friday ?) even if we notice that this method gives more weight to the pre-holidays in the calculation of the average Banks have to report ‘zero’ for no business days? At consolidated level it could be possible that, for some banks belonging the group , the holidays are not in the same date. The reporting bank has to report for these days only the amount referred to the subsidiary that is operating? Or they have to drag the amount of the previous day of the other omponent of the group that are on holiday in that date?

  • 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

ITS ESG P3 - Non-financial risks and value chain

1. Should entities report their own non-financial risks arising from its own operations, or only the non-financial risks related to the operations of its counterparts and customers? 2. If “counterparts” includes the latter then; what is the definition of a “counterpart” ? Does it include the third party value chain e.g. suppliers and outsourcing agreements?

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

ITS ESG P3 - Annex II, Templates 1, 2, 4, 5

With regard to exposures for template 1 and 5, should loans, debt and equity instruments to financial corporations be excluded from reporting and, if so, on what basis? Should exposures to financial corporations be included? With regard to template 1 Column (b): Should exposures to counterparties that are excluded from the EU Paris-aligned Benchmarks be reported only for public companies?     Column (c): Please confirm that the ‘of which environmentally sustainable (CCM)’ column is only required for disclosure as of end 2023? Column (j): For scope 3 emissions of counterparties: Should the PCAF and EU benchmarking sector-specific “Scope 3 phased in approach” be adopted, where only scope 3 emissions for coal, oil gas etc. be reported (from end 2020 onwards), etc.” (see here below from the EU Benchmarking directive)? With regard to template 2, columns (h) to (n), which database should be used for buildings with EPC Labels?  With regard to template 4 Point 21: would it be acceptable for reporting institutions to use various data providers?  Is “carbon intensity” meant to include scope 3 emissions or solely scope 1 and 2? If scope 3 emissions are included, should only reported data be included or include estimated data? Should disclosures refer only to CO2 or to all greenhouse gases in CO2 equivalent?​ Is this a footprint (i.e., absolute emission) or intensity (e.g., relative based on turnover, production or the like) metric? If intensity, what is the denominator? At what cadence should the list of companies be updated? Are the ‘Top 20 Carbon-Intensive Firms’ with respect to a world-wide comparison? Column (a): Does ‘Gross carrying amount (aggregate)’ require banks to report the total gross carrying amount of their banking book and part (b) ‘Gross carrying amount towards the counterparties compared to total gross carrying amount (aggregate)’ require the reporting of the ratio of the carrying amount towards the top 20 emitting companies to the total gross carrying amount? Column (c): is the ‘of which environmentally sustainable (CCM)’ column only required for disclosure as of end 2023? Column (d): is the ‘weighted average maturity’ only required for the carrying amount for counterparties among the top 20 carbon emitting companies? With regard to template 5  General: What point in time and what climate change scenario should the exposure be assessed?  Point 24: ​'Should reporting institutions report separately for different geographic regions, i.e., a separate excel sheet per geographic region and, if yes, what would be the appropriate level of detail for such regions?​ Does the 'breakdown by geography of location' imply that the exposure should be assessed at the location level and overall aggregated exposure across all regions be reported?​ Point 25: are third party data providers’ hazard models for the identification of geographies prone to climate hazards?

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

Cash pool assets in C 47.00

As per ITS of C47, Cash pool assets are to be reported in C47 Rows 0193 to 0198. [1] As net amount of cash pool asset for the group entity are likely to reported in Row 0190, of C47 as other assets. Is it not double counted to the extent of amount reported in Row0190 with regard cash pool assets? [2] As there is validation (v4456) between C47 Rows 0010 to 0290 = C43 total assets, where are these cash pool assets as reported in C47 are to be reported in C43? [3] Whether Cash pool assets as reported in C47 are also to be reported including positive and negative amounts. [4] Is the scope of prudential netting mentioned under article 429b, applicable only for Leverage ratio or does this prudential netting has some thing to do with prudential report applications like COREP?   

  • 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

Securities lent under sale accounting

As per ITS, in line with article 429e (6) of CRR2, The value of securities lent in a repurchase transaction that are derecognised due to a sales accounting transaction under the applicable accounting framework are to be reported  Row 230 of C47. [1] For such repurchase transactions under sale accounting, cash received part is to be allocated in Row 0190 of C47? So also in C43 and C40 the same rule applies? In 47, Row 010, securities under sale accounting are not to be reported as they are expected in Row 230 of C47. [2] The same rules apply to C48 with regard to columns of rows in C47 0010 to 0050, which are to be reported in C48.02 in line with ITS. The validation rule v10094_m expects Row0010 |Col0020 >= Row0010|Col0030 Is this possible as only reverse repo leg and add-on are expected in Col0020 are to be higher or equal to the value of  securities lent under sale accounting are to be reported in Col0030?  [3] As per EBA guidelines, where the institution adopts sale accounting of repo, they should reverse such transactions and report in COREP reports including Leverage ratio. It means, except for the change for securities under sale accounting are to reported in Row 230, while the institution which does not adopt sale accounting are to report own securities under Row0190. Except for this change, add-on and other calculations are same. Please confirm. 

  • 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

ITS ESG P3 - EU Taxonomy Consolidation scope

Which consolidation scope is appropriate for the EU taxonomy disclosures in P3 ESG, given the conflicting regulatory guidance from the EU taxonomy and the NFRD and given that the EU taxonomy is disclosed in the annual report and therefore, the consolidation scope we would prefer to apply is the IFRS consolidation scope rather than the prudential scope?

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

Definition of "accounting value" for the purpose of template C 80.00

Should the assets, except for the derivatives contracts,  be presented in template C 80 from Regulation (EU) 451/2021 as gross accounting value (not affected by  general and specific allowances) or as net (affected by  general and specific allowances)? 

  • 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

Application of NPE prudential backstop in connection with the new COREP templates

The application of the requirements of Articles 47a, 47b and 47c of the CRR is connected with a new COREP reporting requirement for NPE loss coverage envisaged in templates C 35.01, C35.02 and C 35.03. When filling that new COREP reporting templates a the following question has appeared: do all three or any of COREP 35 reporting templates include NPE for which 100% of impairments was already made, that have accounting exposure value of 0 and 100% of specific credit adjustments?

  • 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

ITS ESG P3 - Template 5 - Column B carrying amount

In ESG disclosure template 5: Should the amounts disclosed in column b be equal to the carrying amounts disclosed in column a in template 1, or; Should the amounts in column b only include exposures exposed to physical risk according to the definition in the new Article 18a § 1c?

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

ITS ESG P3 - Template 5 - Physical risk models - Template 1 - Power generation thresholds

Question 1: Regarding power generation thresholds as outlined in the EU article 12.1(g) of the EU Paris-aligned Benchmarks Regulation referenced in Template 1: “companies that derive 50 % or more of their revenues from electricity generation with a GHG intensity of more than 100 g CO2 e/kWh.” (a) Should we look at % revenue by separate sources of fuel or %revenue for the combined fossil fuel power generation of this company? (B) This can be interpreted as a dual factor (revenue from power generation and power generation carbon intensity). What happens if one of the factors is fulfilled, i.e. more than 50% of revenue from power generation, but not the other, i.e. less than 100 gCO2e/kWh. Question 2: Regarding Template 5, do banks need to include exposures based in non-EU geographies? There is no explicit guidance on Template 5. Question 3: Regarding Template 5, we would propose a physical risk assessment for the REMIND NDC climate change scenario (roughly 3 degree global warming in 2100) for the year 2050 (and also with data for “today” ). Is this in line with what the EBA expects? Question 4: Regarding Template 5, which option below is the correct information to fill out for column (j) “of which exposures sensitive to impact both from chronic and acute climate change events”? Question 5: Under which circumstances do banks outside the EU (e.g., Switzerland, UK or US Banks) need to report under EBA Pillar 3? Will the EBA provide a list also for these non-EU based banks falling under EBA Pillar 3?

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

Deductions

The capital items and instruments in the NSFR shall be reported prior deductions. The deductions should be reported as other assets with a RSF of a 100% (Article 429o, point (a), CRR). Should the off-balance deductions be reported on this row as they need an associated RSF, or they shouldn’t be reported at all?

  • 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