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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

Incoherent formulae on the validation rule v0478_m

Should the validation rule v0478_m be active?

  • 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_7854
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 15/10/2026

IPRE and Property Collateral for Credit Risk Mitigation

When assessing the eligibility of immovable property collateral for the purposes of credit risk mitigation (CRM), how should institutions interpret the interaction between the definition of income‑producing real estate (IPRE) exposures in Article 4(75b) CRR and the conditions set out in Article 199(2) CRR for recognising immovable property as eligible collateral under the IRB approach? In particular, can immovable property collateral be recognised for CRM purposes under Article 199(2) in situations where an exposure is classified as IPRE under Article 4(75b), where repayment of the exposure is supported by diversified rental income streams across multiple properties or tenants, such that the repayment of the facility does not materially depend on the performance or cash flows of any single underlying property?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7898
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 09/10/2026

Application of the currency mismatch treatment to self-employed individuals (natural persons carrying out an economic activity) under Article 123a CRR.

Does the currency mismatch treatment set out in Article 123a of Regulation (EU) No 575/2013 (CRR) apply to exposures to self-employed individuals (natural persons carrying out an economic activity), where such individuals are natural persons that meet the criteria of Article 123 CRR, even if they are considered SMEs in accordance with Article 5(9) of CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7724
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 31/07/2026

Requirements for the purpose of treating exposures secured by mortgages on immovable property as duly secured from an RWA computation perspective under CRR Article 124(2) of the CRR.

Can a global insurance against damages on a portfolio of exposures secured by immovable properties subscribed directly by the lending institution be considered as compliant with the requirement of Article 208(5) of the CRR - that is to say considered, under the standardized approach, as meeting the operational requirements for the purpose of treating exposures secured by mortgages on immovable property (or in case an institution has opted for the application of article 108(5)(a) allowing to consider a guaranteed exposure as an exposure secured by a mortgage on immovable property) as duly secured from an RWA computation perspective under Article 124(2) of the CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7293
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 08/05/2026

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

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

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

AIRB combined with Financial Collateral Comprehensive Method

Article 223 para 4 subpara (b) indicates that banks using the A-IRB approach can also utilize the Financial Collateral Comprehensive Method (FCCM). Does the EBA agree with this?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7382
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 31/10/2025

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

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

Reporting of COREP_OF C10.00 template

Are credit institutions that apply the Standardized Approach (SA) for credit risk and the Internal Model Method (IMM) for counterparty credit risk, in order to calculate exposure amounts of SA exposures, required to report template C10.00 row 0270 (Memo item)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2025_7433
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 19/09/2025

Instructions for Row 0080 COREP template C 07.00

Should contractual arrangements that meet all of the conditions set out in Article 5, points (10)(a) to (e) of the CRR, be reported in the row 0800 of the template C 07.00?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2025_7402
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 19/09/2025

Maturity floor for SFT transactions under a master netting agreement that does not fulfill the enforceability criteria of CRR Article 206.

Does the EBA recognise that Securities Financing Transactions (SFT) conducted under an industry master netting agreement (MNA) such as GMRA or GMSLA could be subject to the 5-day floor maturity under CRR Article 162(2)(d) to the extend such MNA (i) meets the requirements of CRR Article 207 (2) to (4) on the eligibility of the collateral but (ii) does not necessarily fulfill the close-out netting enforceability criteria of Article 206 due to local law and absence of robust netting legislation for instance? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7397
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 01/08/2025

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
  • ID: 2024_7213
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 04/07/2025

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
  • ID: 2024_7141
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 04/07/2025

Definition of default for open-end investment funds

Should an open-end investment fund be considered an obligor under Art. 178 (1) CRR, irrespective of whether it has legal personality under a Member States’ regulations on investment funds?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6925
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 21/03/2025

Unterstützungsfaktor für Infrastrukturprojekte - Supporting factor for infrastructure projects

Können sowohl der in Artikel 501 CRR genannte Faktor zur Unterstützung von KMU als auch der in Artikel 501a CRR genannte Faktor zur Unterstützung von Infrastruktur auf eine Risikoposition angewandt werden?Can the supporting factor for SMEs referred to in Article 501 CRR and the infrastructure supporting factor referred to in Article 501a CRR both be applied to an exposure?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5551
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/10/2024

Maturity calculation under IRB for undrawn credit facility

Does Article 162(2)(a) of Regulation (EU) No 575/2013 (CRR) apply to exposures in the form of undrawn credit facilities as the only contractual cash flow payments for the undrawn credit facility are fee-related?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6891
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 21/06/2024