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List of Q&A's

Reporting framework 4.0 Validation rules

Could you please confirm whether validation rule v23722_m is incorrect and should be amended, as it only counts time buckets greater than 7 years, which appears inconsistent with the ITS requirements?

  • 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_7418
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 23/05/2025

Reporting framework 4.0 Validation rules release (new format) (Uploaded on 19/12/2024)

Could you please confirm whether validation rule e4900_n is incorrect and should be amended by removing r0190 from the rule and validation rule v0313_m is incorrect and should be amended by adding r0210 to the rule?

  • 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_7417
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 23/05/2025

Validation rules taxonomy V4.0 C_08.01.a,C_09.02 - v1672_m

The validation rule formula v1672_m specifies that the Risk Weighted Assets (RWA) after supporting factor in column 0125 reported under form 09.02 for IRB exposure class corporates – purchased receivables of all country should be equal to RWA reported under form C_08.01.a, column 0260 where Sheet is in qAE:qx2075 (Corporates - Purchased receivables with own estimates of LGD or conversion factors). The Sheet qAE:qx2076 (Corporates - Purchased receivables without own estimates of LGD or conversion factors) should also be considered in the formula for comparison of exposure to corporates – purchased receivables (with and with-out own estimates of LGD or conversion factors). This Sheet qAE:qx2076 is also a part of validation rules v0435_m, v0436_m and v0438_m where a similar comparison is made for original exposure, Exposure at Default (EAD) and RWA pre supporting factor. The control seems incoherent. Can you please confirm the sheets which need to be included for comparison of corporates – purchased receivables between forms C_08.01.a and C_09.02?

  • 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_7409
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 23/05/2025

Validation rules taxonomy V4.0 C_08.01.a,C_09.02 - v0418_m

The validation rule formula v0418_m specifies that the Risk Weighted Assets (RWA) reported under form 09.02 for IRB exposure class central governments and central banks of all country should be less than or equal to RWA reported under form C_08.01.a, column 0255 where Sheets are in qAE:qx2021 (Central governments and central banks with own estimates of LGD and/or conversion factors), qAE:qx2020 (Central governments and central banks without own estimates of LGD or conversion factors), qAE:qx2014 (Corporates - Specialised Lending without own estimates of LGD or conversion factors), qAE:qx2055 (Retail exposures - Purchased receivables - with own estimates of LGD or conversion factors). The Sheet qAE:qx2014 and qAE:qx2055 should not be considered in the formula for comparison of exposure to central government and central bank. These two sheet’s codes are also not part of validation rule v0415_m and v0416_m where the similar comparison is made for original exposure and Exposure at Default (EAD). The control seems incoherent.

  • 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_7408
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 23/05/2025

Disclosures of Number of Staff Management body in its supervisory function in FINREP Template 44.4

For the management body in its supervisory function and senior management in Template 44.4 column 0040, and management body in its management function in column 0030, should only the number of members of the management body and senior management in EU parent company be reported, or should the number of members of the consolidated subsidiaries also be included? Same question applies to the variable and fixed remuneration rows 0010 and 0020, and other staff expenses row 0030.

  • 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: 2025_7406
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

FINREP – Template 40 Group structure (40.1 “entity-by entity” – 40.2 “instrument-by-instrument”) – Notion of Group scope

Could you clarify if the associated companies whose holder is a group company that consolidates within the prudential scope by equity method should be included individually?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2025_7399
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

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:

Calculation of minimum lease payments in case of operational lease

Does the EBA acknowledge that the residual value should be discounted, or the interests on this residual value should be filtered out of the calculation of the discounted minimum lease payments, to avoid an increase of the exposure beyond the accounting value?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7393
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 21/05/2025

Multilateral development banks classification for the purpose of article 325ah

Buckets 2 and 11 of Table 4 in Article 325ah refer to the category of multilateral development banks (MDBs) and international organisations (IORGs) referred to in Article 117(2) or Article 118 of CRR. At the same time, paragraph 2 of the same article 325ah, requires the use of a classification that is commonly used in the market for grouping issuers by sector, in order to assign a risk exposure to a sector.  Assuming that such a market wide accepted classification would show a certain counterparty as an MDB, as long as this specific counterparty is not listed in the above listed articles mentioned for buckets 2 and 11 of Table 4 in Article 325ah (as a one to one match) , then this counterparty would need to be assigned to a different bucket, likely 4 or 13.  Can there be a departure from the specific list of MDBs and IORGs, as referred to in Article 117(2) or Article 118 of CRR, for the purpose of Table 4 in Article 325ah of CRR? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7391
  • Topic: Market risk
  • Date of submission:

Valuation of non-CET1 instruments

As per the EBA REPORT ON THE MONITORING OF ADDITIONAL TIER 1 (AT1), TIER 2 AND TLAC/MREL ELIGIBLE LIABILITIES INSTRUMENTS OF EUROPEAN UNION (EU) INSTITUTIONS – UPDATE document published on the 27th of June 2024, paragraphs 145 to 151, the report advises to include the accrued interest in the amount used for the valuation of such instruments, i.e., the carrying amount in full, for prudential purposes. This however has not been included in any ITS on Corep or MREL that we are aware of. Could you please advise if this change should have a direct impact on the amounts reported in Corep or MREL, whether it is mandatory for all reporting entities and if so, starting with which reference date/reporting framework?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7389
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 03/06/2025

Application of formulae v23061_m on r0180

Could you please confirm that the formulae v23061_m needs to be modified and should apply to all rows except r0180?

  • 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_7385
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 23/05/2025

currencies Lithuanian Litas and Croatian Kuna

In C 22.01 the currencies Lithuanian Litas and Croatian Kuna are still available in the Annotated templates, while removed from C_2024_8389_1_ANNEX_EN_V3_P1_3682615.XLSX, which was published after the Annotated templates. Can we assume these 2 currencies should be removed?

  • 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_7384
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 23/05/2025

Financial Conglomerates: Mismatch between ITS and DPM 3.5 – ID v22748_u - T1 L 06.00, column c0020.

We are seeking clarification about a possible mismatch between ITS and DPM 3.5 (ID v22748_u - T1 L 06.00, column c0020) as part of the compilation of the template FC.06 Template - “Risk Concentration - Exposure by counterparties" within the FiCod. supervisory reporting. The Commission Implementing Regulation (EU) 2022/2454 of 14 December 2022 states that, within the Template FC.06 - “Risk Concentration - Exposure by counterparties", the exposures must be reported for each individual legal entity belonging to the financial conglomerate, whereas the DPM 3.5 only permit reporting a unique value of the identification code of the external counterparty. This also determines the impossibility of representing separately the exposures held towards the same external counterparty but denominated in different currencies. We therefore ask what is the correct way to represent - inside the FC.06 Template- the cases in which multiple entities belonging to the conglomerate have exposures towards the same external counterparty and for the cases in which, for each external counterparty, there are exposures denominated in different currencies.

  • Legal act: Directive 2002/87/EC (FiCOD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2454 – ITS on the reporting of intra-group transactions and risk concentration for financial conglomerates
  • ID: 2025_7381
  • Topic: Financial conglomerates
  • Date of submission:

v7364_m

Is v7364_m complying with the CRR?

  • 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_7380
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 23/05/2025

SME

In the instructions for Finrep ITS consolidated - Annex V to EU Regulation 2021/451 - there is a definition of SME in point 5.i ‘SME’: micro, small and medium-sized enterprises as defined in Commission Recommendation C(2003)1422 (6); (Commission Recommendation of 6 May 2003 concerning the definition of micro, small and medium-sized enterprises (C(2003)1422) (OJ L 124, 20/05/2003, p. 36), where in article 1: “Enterprise An enterprise is considered to be any entity engaged in an economic activity, irrespective of its legal form. This includes, in particular, self-employed persons and family businesses engaged in craft or other activities, and partnerships or associations regularly engaged in an economic activity.” In accordance with the above-mentioned recommendation and SME definition, the scope  of enterprises also includes self-employed individuals. Given that SME are reported in FINREP ITS as enterprises,  should self-employed entrepreneurs be treated as enterprises as well?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2025_7379
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 22/05/2025

Identical Cell Template C 10.00

Can you confirm that the definition of these cells as identical cells is correct?

  • 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_7378
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Calculation of the Countercyclical Capital Buffer

Clarification  to EBA Q&A 2016_3050 and CRM techniques with substitution effects How do we have to consider CRM techniques with substitution effects on the exposure in the CCB?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7377
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 23/05/2025

Recognition of non-transferable liquidity held by and arising in third country subsidiaries in the context of the calculation of the consolidated LCR

What is the (combined) treatment of liquid assets held by and liquidity inflows arising in third country subsidiaries being subject to transfer restrictions for the purpose of the calculation of the LCR at consolidated level?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement
  • ID: 2025_7375
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 27/03/2025

C_25.01.b Datapoint Modelling

The datapoint modeling for C_25.01.b does not align for rows 10 & 20 with that of C_25.01.a. The datapoint model for C_25.01.a lists (qAFF:qFI) Type of Financial Instruments while C_25.01.b does not. 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7371
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 23/05/2025