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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

Reporting of gains/losses other than dividends for investments in subsidiaries, associates and joint ventures (F 02.00).

Could you please provide further instructions about the reporting of gains/losses other than dividends for investments in unconsolidated (with respect to the regulatory scope of consolidation) subsidiaries, associates and joint ventures in the statement of profit or loss (F 02.00)?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2019_4621
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/06/2020

Benchmark Rates of other currencies than EUR, USD, GBP

Can you kindly confirm: - Currencies other than the three currencies mentioned in Point 3(b) namely EUR, USD and GBP must be compared to the benchmark in the same currency - For currencies that are not captured by LIBOR (e.g. CAD, RON), we should apply the benchmark rates set by the respective organisation (e.g. Romania Three Month Interbank Rate for RON).

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2019_4616
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 08/05/2020

Definition of "external customers" mentioned in iii) of b) of Paragraph 1 of Article 96

Could it be possible to give a definition of "external customers" mentioned in iii) of b) of Paragraph 1 of Article 96? Would an entity from the same banking group (in the case of an investment firm belonging to a banking group) be considered as an external customer?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/63 - DR on ex ante contributions to resolution financing arrangements
  • ID: 2019_4613
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

FINREP F01.03, F02 and F46 checks (V1226_m and V0786_m)

The non-xbrl check V1226_m is in contradiction with v0786_m

  • 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: 2019_4612
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 08/05/2020

FINREP Validation rule v2822_m

V2822_m: sum({F 32.01, r110, (c010, c060)}) = sum({F 05.01, r090, (c020-060)}) - Economic agents inconsistency : F 32.01, r110, (c010, c060) = non-financial corporation and households; F 05.01, r090, (c020-060) = all agents

  • 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: 2019_4611
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 17/07/2020

Identification and access for testing purposes of entities that are not authorised third party providers (TPPs)

How would account servicing payment service providers (ASPSPs) identify entities that have applied for authorisation as a TPP?Should ASPSPs offer access to their testing facility to entities that are not (i) authorised payment service providers or (ii) entities that have applied for authorisation as a TPP (e.g. technical service providers)? If the answer is ‘yes’, should ASPSPs offer the same level of service to the referred entities?

  • 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: 2019_4609
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 29/03/2019

Scope - Limited network exclusion

Is there a geographical limitation with regard to a limited network of service providers?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4604
  • Topic: Authorisation and registration
  • Date of submission:
  • Published as final Q&A: 21/01/2022

ASPSP providing updated payment status to PISP

Are account servicing payment service providers (ASPSPs) required to provide information on the initiation and execution of the payment transaction, including updates, in order for a payment initiation service provider (PISP) to comply with Article 46(a) PSD2 and pursuant to Article 36(1)(b) RTS?

  • 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: 2019_4601
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Application of national decisions pursuant to Article 124(2) CRR

Is it mandatory pursuant to Article 124(5) CRR for an institution in another member state to apply national decisions, which purport to be released pursuant to Article 124(2) CRR, but are not published on the EBA website under Rules and Guidance?Furthermore, if such national decisions are not published under Rules and Guidance, but e.g. under Options and national discretions only, is it mandatory that institutions from other member states apply such decision pursuant to Article 124(5) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4600
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 17/09/2021

Calculation of the number of obligors

In EBA/GL/2017/16 paragraph 73 it is explained that in the calculation of the one-year default rates the number of obligors is used. Is it always mandatory to count one legal entity as one obligor, or can a group of legal entities for which there is no difference in risk due to an appropriate guarantee (i.e. those will default together) be counted as one obligor?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/16 - Guidelines on PD estimation, LGD estimation and the treatment of defaulted exposures
  • ID: 2019_4599
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Use of rating before or after transfer in the calculation of the one-year default rates

In a situation where a parent institution (good rating) has issued a full encompassing guarantee for a subsidiary - bad rating, thus supporting the subsidiary before a default event, and preventing (or reducing the risk of) a default – would this constitute a substitution effect due to a credit risk mitigation under paragraph 74 of EBA Guidelines EBA/GL/2017/16?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/16 - Guidelines on PD estimation, LGD estimation and the treatment of defaulted exposures
  • ID: 2019_4598
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 04/12/2020

Ready access to bonds giving natural hedging to the banking book

Can HQLA assets whose sale would result in a breach of internal limits for IRRBB be considered as free and readily accessible under Article 8 of Commission Delegated Regulation (EU) 2015/61?

  • 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: 2019_4596
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Definition of an electronic remote payment transaction

What are the demarcation criteria of the term „remote payment transaction“, which is an essential term in the RTS on SCA and CSC?

  • 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: 2019_4594
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 21/01/2022

Validationrule v5713_s DPM2.8 FINREP F 46.00

Our question relates to EBA validationrule v5713_s which, in our view, is not always applicable. This validation rule applies to the situation where a dividend distribution is done from "Capital"; the first column. In this situation the amount of dividend should be negative in c_010, r_110 of template F46.00. However, there can also be the situation that a stock dividend is converted from Share premium to Capital. In this situation there is a negative amount reported in the second column "Share premium" and there is an equal positive amount in the column "Capital" disclosed. The total change in equity is nil, but there is a shift from Share premium to Capital. In this situation should it be possible to report a positive amount in the column "Capital". Is our understanding correct ?

  • 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: 2019_4591
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 08/05/2020

Retail exposures of subsidiary / branch of an EU credit institution established outside the EU

Could the subsidiary / branch of an EU credit institution established outside the EU use local criteria (i.e. criteria widely used by credit entities and public bodies in the relevant foreign jurisdiction) to classify an undertaker as a small or medium-sized enterprise in order assign to its exposures a risk weight of 75% according to Article 123?Could the subsidiary / branch of an EU credit institution established outside the EU use local criteria (i.e. criteria widely used by credit entities and public bodies in the relevant foreign jurisdiction) to classify an undertaker as a small or medium-sized enterprise in order assign to its exposures a risk weight of 75% according to Article 123?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4590
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 31/07/2020

Requirement on the use of a Qualified Certificate for Electronic Seals (QSealC) for integrity and authenticity

Please clarify  whether in the EBA’s Opinion on the use of eIDAS under the RTS on SCA and CSC, under Paragraph 11, Qualified Electronic Seals employing a Qualified Seal creation Device are required to provide integrity and authenticity through the reference to Article 35(2) of Regulation (EU) No 910/2014?

  • 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: 2019_4586
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 14/06/2019

Provisions as part of the own funds

Can provisions that are made against loss events in the past (i.e. previous accounting periods) be used as a capital substitute to cover future losses? Are these provisions available with a high degree of certainty?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4583
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Clarification on the reporting of "maturing" columns in COREP ALMM C 70.00 "Roll-over of funding"

In the "Maturing" columns of C 70 .00, do we have the option of reporting in two different ways? We can either report "Maturing" amounts according to all liabilities contractually withdrawable by the providers of funding for each day of the month. Or we can report only the amounts "Maturing" which are due on the relevant day.

  • 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: 2019_4581
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 17/07/2020

Treatment for the intragroup derivative liabilities in the methodology to calculate ex-ante annual contributions to the Single Resolution Fund

Are there any provisions preventing to apply the same treatment for the intragroup derivative liabilities and for the other derivative liabilities as mentioned in Paragraph 4 of Article 5 of Delegated regulation (EU) 2015/63 ?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/63 - DR on ex ante contributions to resolution financing arrangements
  • ID: 2019_4577
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Surcharging

Is a ‘foreign exchange margin’ or 'currency conversion fee'  different from a ‘surcharge’ and do different foreign exchange margins above the ECB mid-market rate not constitute a surcharge?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4576
  • Topic: Other topics
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022