Single Rulebook Q&A

Question ID: 2017_3424
Legal act : Regulation (EU) No 575/2013 (CRR)
Topic : Supervisory reporting
Article: 99
Article/Paragraph : Anexes I and II
COM Delegated or Implementing Acts/EBA RTS/EBA ITS/EBA GLs: Draft ITS on Supervisory Reporting of Institutions
Subject matter : Reporting requirements for template C 33.00

How shall exposures to entities that are classified differently between different reporting frameworks (i.e. FINREP and COREP) be assigned to an exposure class in Template C33?

Background on the question:

Paragraph 156 of Annex II to EBA/ITS/2017/01 defines the scope of the data contained in C 33.00 as follows: ‘156. Exposures to ‘General governments’ are included in different exposure classes in accordance with Article 112 and Article 147 of CRR, as specified by the instructions for the completion of template C 07.00, C 08.01 and C 08.02.’

In accordance with the aforementioned paragraph 156, exposures shall be connected to the risk exposure classes that are defined in template C 33.01. According to the OeNB newsletter regarding new reporting requirements (, all reporting based on ESVG must apply the classifications regarding the public sector (

COREP does not currently provide for this treatment. This gives rise to the following situation: an exposure to an entity mentioned in the list in the link from Statistik Austria above is assigned in FINREP to ESVG Sektor S.1313 (local government) in accordance with Statistik Austria’s ‘Classification of institutional sectors – as of March 2017’ and subsequently to FINREP economic sector ‘General governments’. In COREP, an exposure to this entity is assigned to exposure class ‘Corporates’ (see Articles 122 and 123 CRR) and subsequently cannot be reported in detail in template C 33.00.

Date of submission: 27/07/2017
Published as Final Q&A: 17/11/2017
EBA answer:

The European System of National and Regional Accounts (ESA 2010) has been used as a basis on which to report counterparty sector information in certain templates of Annexes III and IV (FINREP) to Regulation (EU) No 680/2014 (ITS on Supervisory Reporting); see Q&A 2015_1758.

According to ESA 2010, the general government sector consists only of institutional units that are non-market producers. Thus, a corporation controlled by the government and assessed as a non-market producer in the meaning of ESA 2010 leads to the classification ‘Central government’ in FINREP (ESA 2010), but may lead to a classification as ‘Corporate’ for the purposes of calculation of own funds requirements for credit risk (Article 112 (g) of Regulation (EU) No 575/2013 (CRR)).

The exposure classes listed in rows 040 to 070 and 090 to 150 of template C 33.00 of Annex I to the Draft ITS on Supervisory Reporting (EBA/ITS/2017/01) do not provide an exhaustive list of all possible exposure classes. Exposures to general governments corresponding to an exposure class other than those listed in the aforementioned rows of template C 33.00 shall thus be reported in the total rows 030 (Standardised Approach) and 080 (IRB Approach), as applicable, but not in any of the rows 040 to 070 or 090 to 150.


The present Q&A on Supervisory reporting is provisional. It will be reviewed after the Implementing Regulation is in force and published in the Official Journal. The text of the Implementing Regulation may differ from the text of the draft ITS to which this Q&A refers.


Status: Final Q&A
Permanent link: link