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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

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
  • ID: 2025_7342
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 11/04/2025

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
  • ID: 2025_7335
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 11/04/2025

Definition of Delta GIRR risk-free interest rate curves

Which risk-free interest rate curves per currency should be considered as different curves? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7334
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 11/04/2025

Intragroup transactions in calculation of net positions and own funds requirements for FX risk

i)When calculating the entity level positions and own funds requirements under Article 325b(4), are intragroup transactions allowed to be included ? ii)Same question for Article 352(2) determination of consolidated structural position

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7276
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 11/04/2025

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)”,  should the denominator used in the calculation of the percentage be: the gross carrying amount of exposures which GHG emissions are available or estimated  OR the gross carrying amount of all the exposures within the banking book portfolio regardless of whether the GHG emissions are available, estimated or not available (missing).

  • 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: 2024_7225
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 11/04/2025

Operational risk – gross loss in tax related events in accordance with REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) No 575/2013 as regards requirements for credit risk, credit valuation adjustment risk, operational risk, market risk and the output floor, Article 318.

How should an institution calculate gross loss based on the regulatory changes stipulated in Article 318. of the Regulation amending Regulation 575/2013 in the following examples? Case 1 – Delayed tax payment, penalty interest payment, and system repairment expenses Case 2 – Delayed tax payment, no penalty interest payment, system repairment expenses.  Case 3 – Tax to be paid for this year and previous years, no penalty interest, or fine, financial reports for previous year to be revised and re-published.  Case 4 – Tax to be paid for this year and previous years, no penalty interest or fine, no changes to financial reports for previous year.  Case 5 – Tax to be paid for this year and previous years, penalty interest and fine, financial reports for previous year to be revised and re-published Case 6 – Tax to be paid for this year and previous years, penalty interest and fine, no changes to financial reports for previous year   

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7107
  • Topic: Operational risk
  • Date of submission:
  • Published as final Q&A: 11/04/2025