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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. 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

ITS ESG P3 - Template 2 - Column A & Totals in row 5 and 10

Two questions with regard to Template 2:  Banking book - Climate change transition risk: Loans collateralised by immovable property - Energy efficiency of the collateral: 1) Should the columns h-p sum up with b-g and simultaneously with the column a? 2)  In which lines to report a situation in which the bank estimates the energy efficiency of collateral a housing mortgage? Should rows 5 and 10 be a sum of rows 2-4 and 7-9 respectively?

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

Assets which are not immediately available for monetisation in C 66.01

In relation to the reporting of the C 66.01 maturity ladder template, what is the treatment of assets which are generally eligible as counterbalancing capacity but which, from the perspective of the reporting institutions, are not immediately available to cover potential contractual funding gaps?

  • 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 1 - Scope 3 & Sector average emissions intensity

Three questions with regard to Template 1: Banking book- Climate Change transition risk: Credit quality of exposures by sector, emissions and residual maturity: 1) column I: How to understand this instruction relating to Scope 3: The estimation of scope 3 emissions per sector shall be done in a proportionate way: e.g. by taking the institution’s exposures (loans and advances, debt securities and equity holdings) towards the counterparty compared to the total liabilities (accounting liabilities and shareholders’ equity) of the counterparty? 2) column I: How will the bank use the estimates of "sector avarage emissions intensity" in template 1? 3) What type of data should the bank disclose in scope 1 and 2? In the template 1 table, there is a separate column for Scope 1, 2, and 3, and separate for Scope 3 itself. Scope 1 and 2 are the consumption of the organization, they do not concern financing – what exactly is the bank to report there?  Full Scope 1 and 2 of  clients or in some proportion?

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

Calculation of goodwill included in the valuation of significant investments in insurance undertakings

A. For the purposes of a deduction under Article 36(1)(b) CRR, should the goodwill (Article 4(1) no. 113 and 115 CRR)  included in the valuation of significant investment                      be calculated at the acquisition date by separating any excess of the acquisition cost over the banking group’s share of the net fair value of the identifiable assets and liabilities of the insurance undertaking or be the amount disclosed as goodwill in the IFRS/NGAAP consolidated balance sheet of the parent institution (or parent financial holding company or parent mixed financial holding company, as applicable) in proportion of the participation recorded for prudential purposes (i.e. in case of participation of 100%, the full goodwill should be deducted, including also goodwill generated at the level of the insurance undertaking)?    B. Would the application of Article 49(1) CRR provide the possibility to risk weight rather than deduct the goodwill included in the valuation of significant investment in insurance undertakings?

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

Definition of exposures arising from mortgage lending

Which value of the exposure is the amount that can be reduced, when referring to "the pledged amount of the market value or mortgage lending value of the property concerned, but by not more than 50 % of the market value or 60 % of the mortgage lending value”?

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

Clarification of the relationship between EBA's Guidelines on outsourcing arrangements and Section 4 of the Directive (EU) 2015/849 - AML

Does the term of outsourcing (paragraphs 12 and 26) of EBA GL/2019/02 include performing of customer due diligence by third parties under Section 4 of the AMLD4, i.e. whether or not the application of GL/2019/02 to Performance by third parties would be in violation of the AMLD4?

  • Legal act: Directive (EU) 2015/849 (AMLD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

SCA for token replacement

Is SCA required for the replacement of a tokenized card happening in the background without any ‘action by the payer’ under Article 97(1)(c) PSD2 in the following cases: Expiry of the token and update of the token Replacement of the card, and the new card has a different BIN/Account Range (e.g., for product graduation, such as standard to gold, or simple BIN management) and/or different functionalities Technical and/or configuration changes to the issuer’s BIN configuration (such as migrating from 6 to 8 digit BINs) In all these cases, the existing tokenized credentials have been initially associated with SCA to the user under Article 24(2)(b) RTS, and this is solely a technical replacement of the token. credentials have been initially associated with SCA to the user under Article 24(2)(b) RTS, and this is solely a technical replacement of the token.

  • 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

SCA applicability / Application of SCA at tokenisation stage

Does the authentication to unlock the mobile device count as one of the elements of strong customer authentication when a payment service user is tokenising a card on an e-wallet solution such as Apple Pay?

  • 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

Application of SCA to issuing a payment instrument and tokenisation

Is strong customer authentication (SCA) required when a Payment Service Provider (PSP) issues a payment instrument or creates a token?

  • 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

Consistency of validation rule v3017_m

What is the rationale of the validation rule regarding the subset of 'central bank eligible' collaterals among non-encumbered collateral received between AE-ADV-2 (F 36.02) and AE-COL (F 32.02), where non-encumbered collateral received are reported under a different presentation structure?

  • 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

Adequacy of the validation rule v10684_m - Instruments not at FVPL

v10684_m foresees a reconciliation between F 12.01 and F 02.01 in respect of gains/losses from financial instruments not at FVPL. Why is this validation rule expected to work, considering that (a) it encompasses debt instruments at amortized cost, which are identified as purchased or originated credit impaired assets (POCI) or are attributable to Stage 3 at the date of de-recognition and (b) it encompasses debt instruments at fair value through other comprehensive income?

  • 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

F 44.01 - validation rule v3985_s

How to inform in template F 44.01 of the fair value of certain components (liabilities) of net defined benefit plan assets.

  • 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

Relation between posted cash variation margin in derivative transactions reported in C 47.00, rows 0071, 0190 and 0210

We kindly ask EBA to confirm our understanding regarding the consideration of cash variation margin in C 47.00 or if our understanding is not correct, please give detailed instructions how to consider the variation margin in data points: {0071; 0010}, {0190; 0010}, {0210; 0010} in C 47.00.    (1) By EBA Q&A 2020_5617, the EBA has stated that, preliminary, in data point {0071; 0010} of C 47.00 the value of net eligible cash variation margin received or posted shall be reported according to Article 275 CRR. The amount to be reported here shall be limited to the amount that reduces the replacement cost given in cell {0061; 0010} to zero. Both amounts in {0061; 0010} and {0071; 0010} are multiplied with the factor 1.4. Hence, the amounts of net cash variation margin received or posted reported in {0071;0010} are entirely part of the replacement cost calculation according to Article 275 CRR. We kindly ask EBA for confirmation or correction.    (2) According to Annex XI to Commission Implementing Regulation (EU) 2021/451 receivables for cash variation margin provided where recognized under the operative accounting framework shall also be reported among other assets in position {0190; 0010} of C 47.00, with its valuation according to Article 429b(1) in conjunction with Article 111(1) CRR. Thus, the bank would report in this cell the posted cash variation margin with its accounting value after specific credit risk adjustments and how it’s recognized on the balance sheet, regardless of the treatment of cash variation margin in the positions {0061; 0010} and {0071; 0010} and regardless of the conditions of Article 429c (3) points (a) to (e) CRR. We kindly ask EBA for confirmation or correction.    (3) Annex XI to Commission Implementing Regulation (EU) 2021/451 stated that in data point {0210; 0010} of C 47.00 receivables for variation margin paid in cash to the counterparty in derivatives transactions have to be reported, if the institution is required, under the applicable accounting framework, to recognize these receivables as an asset, provided that the conditions in points (a) to (e) of Article 429c(3) CRR are met. Additionally, the amount reported shall also be included in the other assets reported in {0190;0010}.     Regarding to this instruction, we wonder if the amount to be reported in {0210; 0010} has to be the amount according to Article 429b(1) in conjunction with Article 111(1) CRR (thus its accounting value after specific credit risk adjustments) or the amount calculated in accordance with Article 275 CRR multiplied by the alpha factor of 1.4. But if the amount calculated in accordance with Article 275 CRR has to be reported in {0210; 0010}, due to volatility adjustments on the variation margin, this amount could be higher than the carrying amount of the variation margin posted, reported in {0190; 0010}. This would result in a negative effect on the total leverage ratio exposure measures in {0290; 0010} and {0300; 0010}.     Further, it is stated that the amount reported in {0210; 0010} also has to be included in {0190; 0010}. Does that mean the amount of cash variation margin posted included in both data points has to be equal?  We kindly ask EBA for clarification and answering the question. The credit institution is not subject to NICA and applies German nGAAP. 

  • 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

v09821_m, v09823_m - Hedging sets

In template C 34.03, the columns current market value (CMV), positive (c0050) and Current market value (CMV), negative (c0060) are to be presented on hedging set level and shall be determined by netting positive and negative market values of the transactions within one hedging set gross of any collateral held or posted.  In order to comply with requirements, the CMVs are to be presented on hedging set level. While this is possible for calculating each risk category (e.g. Equity risk (r0230, c0050, c0060), there is a potential issue with split of the given risk category into single- and multi-name transactions (e.g. for Equity risk: r0250, r0260, c0050, c0060). The hedging sets can contain both single and multi-name transactions. How to approach a possible situation where in an extreme case e.g. CMV on the hedging set can be positive, but all single name transaction-level MV are negative, therefore the positive CMV would actually be negative? Is it possible to calculate CMV splitting the hedging sets into single and multi-name hedging sub-sets, then determining the CMV on those hedging sub-sets? In this case, the netting of positive and negative market values will happen only within the hedging sub-sets.

  • 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

FINREP - Treatment of cash collateral

In an earlier issued answer (Q&A 2020_5279), it was advised that cash collaterals on derivatives should be reported as part of 'Financial assets at amortised cost' [F 01.01, r183, c010].  Should cash collaterals on other products, for instance reverse repurchase agreements and repurchase agreements (repos & reverse repos) be treated similarly?

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

Collateral received for derivatives in F 32.04 and F 32.02 with master netting agreements in place

Can the collateral received for derivatives be reported in AE templates F 32.04 (AE-SOU) and F 32.02 (AE-COL) at master netting agreement level (counterparty level), when collateral is only exchanged at that level? 

  • 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

Indication of use of derogation of Article 2(5)(b) of Regulation (EU) No 1152/2014

It is not clear from the instructions which value should be reported to indicate in a harmonised way whether an institution makes use of the derogation stated in Article 2(5), point (b) of Regulation (EU) 1152/2014.

  • 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

Interest income from other assets in F 02.00 and F 16.01

Should ‘Interest income - other assets' be the same in templates F 02.00 and F 16.01 (correctness of validation rule v5598_i and Q&A 4009)?

  • 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

C 33.00: Instructions concerning specific positions - c0020

Should column 0020 in C 33.00 be filled in as the sum of the columns 0030 to 0120 minus column 0130? Or should the net amount only be reported when the following condition is met: there’s a short position with the same immediate counterparty and residual maturity? If the current definition of column 0020 is considered correct, should validations v10651_m and v5853_h be changed?

  • 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