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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.

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List of Q&A's

Exposures to institutions waived from individual capital requirements according to article 7 CRR, under Credi Risk Standarised Approach

How should exposures to institutions be treated under Credi Risk Standarised Approach, if such institutions have been waived of individual capital requirements? Shall these exposures be assigned to grade C, or can the level of compliance with capital requirements be assessed by taking consolidated requirements as reference?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7363
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 24/10/2025

Eligibility as collateral under article 207(2) of secured notes designed specifically to remove any material positive correlation between the value of the note and the credit quality of its issuer.

Entity A issues a secured note designed specifically to remove any material positive correlation between the value of the note and the credit quality of its issuer (entity A). The note is secured by assets uncorrelated to entity A. In legal structure I, entity A deposits the assets with a third-party custodian trust account, pledged to the note holders.  In a variant legal structure II, entity A sells the assets to a SPV, which has been setup by entity A for that sole purpose; the SPV then issues a guarantee to the noteholders, backed by the assets it holds. Bank B enters into a reverse repo with entity A, where it lends cash to entity A and receives the secured note as collateral. From bank B’s perspective, does such secured note qualify as eligible collateral under CRR article 207(2) when: the secured note is secured by the assets held in a third party custodian trust account, pledged to the noteholders (legal structure I)? the secured note is guaranteed by a SPV holding the assets (variant legal structure II)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7470
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 24/10/2025

Sources for external classification that is commonly used in the market for grouping issuers by sector, for the purpose of CRR Article 325ah.

Can lists produced by competent authorities be also seen as meeting the requirement in Article 325ah(2.) (e.g. commonly used market classification)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7400
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 17/10/2025

ESG P3 - Template 1 - Reporting of column k (GHG emissions (column i): gross carrying amount percentage of the portfolio derived from company-specific reporting)

In Template 1, “column k (GHG emissions (column i): gross carrying amount percentage of the portfolio derived from company-specific reporting)”,  could you please clarify how the percentage should be calculated in the total column (56)? In the interest of precision and clarity, it is essential to determine whether the total percentage should be calculated over the total gross carrying amount of the template or only take into account the exposures that contribute significantly to climate change and replicate the same percentage that appears in row 1. This determination is crucial as only emissions from sectors that contribute substantially to climate change should be reported. Example: Exposure Gross Carrying Amount Gross Carrying Amount of the portfolio with derived from company-specific reporting Highly contributing sectors exposure 100 25 Non-highly contributing sectors exposure 200 Not disclosed Total exposure 300 25 The denominator of the row 56 i.e. gross carrying amount used in the calculation of the percentage for column k will be based on 100 or 300? Final result should be: 25% of the portfolio has emissions derived from company-specific reporting 8% of the portfolio has emissions derived from company-specific reporting

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2025_7426
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 10/10/2025

Definition of Net defined benefit assets [Carrying amount] in F44.01

Please can we clarify what is required in row 0090 of FINREP template F44.01 in terms of the "Net defined benefit assets" ? i.e. should this row only include surplus amounts that shall be recognised in the balance sheet given that the previous sign validation rule v3985_s has now been deactivated?

  • 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_7526
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 10/10/2025

Treatment of bridge financing in the calculation of the risk weight (RW*)

As the objective of Article 132c (1) CRR, as amended by Regulation (EU) 2019/876 – CRR2, is to “calculate the risk-weighted exposure amount for their off-balance-sheet items with the potential to be converted into exposures (…)”, should the calculation of RW* actually exclude short-term liabilities (e.g. bridge financing)? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7189
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 10/10/2025

ASF factors for Additional Tier 1 items as wells as Tier 2 items and other capital instruments maturing between 6 month and 1 year

For the purpose of calculating the NSFR, which appropriate available stable funding factor shall institutions apply for Additional Tier 1 items as well as Tier 2 items and other capital instruments maturing between 6 month and 1 year?

  • 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)
  • ID: 2021_6017
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 07/10/2025

Authentication process of the PSU with the ASPSP in a combined AIS and PIS journey in a redirection approach

Consider an ASPSP that offers a dedicated interface using a redirection approach. To fulfill the requirement that PSUs using a PIS should not have to enter their own account details, the ASPSP allows TPPs that have an AIS license to retrieve the list of all the PSU’s payment accounts via the interface so that the account can be selected in the TPP’s domain.  Does the ASPSP create an obstacle in the sense of Article 32(3) of Commission Delegated Regulation (EU) 2018/389 if  it forces a PSU who is initiating a payment through a PISP without entering the own IBAN to perform full SCA twice while a PSU who initiates a payment through the ASPSP’s customer interface needs to perform full SCA only once, while the second authentication requires entering only one element of SCA?

  • 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
  • ID: 2025_7358
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 03/10/2025

the use of strong and widely recognized encryption techniques

All strong and widely recognized encryption techniques (e.g. RSA and ECC) currently available on the market must be provided by the account servicing payment service providers or only that encryption technique which is indicated in the documentation of the technical specification of the API in accordance with Article 30(3) of the RTS on SCA & CSC shall be provided?

  • 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
  • ID: 2025_7376
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 03/10/2025

SCA exception for Contactless only terminals (SoftPOS) in case of emergency

We are in the process of developing a backup solution for our SoftPOS terminal application, intended for use during exceptional circumstances such as cyber-attacks or other disruptions to internet connectivity and acquirer systems. As SoftPOS terminals operate exclusively with contactless transactions, and contactless transactions does not support Offline PIN, it is technically not possible to perform Strong Customer Authentication (SCA) in offline mode. We would like to confirm whether, under these conditions, it is acceptable to process offline contactless transactions without applying SCA and follow Directive (EU) 2015/2366 article 0 (15)

  • 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
  • ID: 2025_7482
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 03/10/2025

Minimum monetary amount of professional indemnity insurance in ongoing supervision

Are points 5.4, 5.7, 5.10 and 7.4 of EBA/GL/2017/08 guideline applicable only while applying for authorisation or in ongoing supervision as well? Is 50 000 per indicator minimal amount after authorisation procedure/first year as well?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/08 - Guidelines on the criteria on how to stipulate the minimum monetary amount of the professional indemnity insurance
  • ID: 2025_7317
  • Topic: Monetary amount of the professional indemnity insurance
  • Date of submission:
  • Published as final Q&A: 03/10/2025