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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

Seniority categories to use when offsetting the gross JTD amounts of short exposures and long exposures within the DRC calculations for non-securitisations 

Which set of seniority categories shall be utilised and how should they be ranked as the basis for offsetting the gross JTD amounts of short exposures and long exposures within the DRC calculations for non-securitisations? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7233
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 17/01/2025

Vega general interest rate risk and credit spread risk factors

For credit instruments that include issuer-specific optionality, do both general interest rate vega and credit spread vega risk factors need to be considered as part of the SBM? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7232
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 17/01/2025

Basis of calculation for the DRC for non-securitisations and SBM-CSR for non-securitisations - instruments guaranteed by a guarantor

In the case of instruments guaranteed by a guarantor (such as guaranteed bonds), can that guarantor be used as the basis for calculating the DRC for non-securitisations and the SBM-CSR for non-securitisations? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7231
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 17/01/2025

Basis of calculation for the DRC for non-securitisations and SBM-CSR for non-securitisations – Individual ‘issuers’/‘obligors’ or ‘group of issuers/obligors’?

Do the calculations of the DRC for non-securitisations and SBM-CSR for non-securitisations have to be based on the individual ‘issuers’/‘obligors’, or could these calculations alternatively be based on the concept of a ‘group of issuers/obligors’ consisting of e.g. a conglomerate (and e.g. represented by an ‘ultimate parent’ corresponding to the ‘head of group’ or ‘parent company’)?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7230
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 17/01/2025

Conditions for increasing the margin period of risk (MPOR) used for the exposure value of netting sets with margin agreements.

Article 285 paragraph 3(b) references “OTC derivative that cannot be easily replaced”. By definition “OTC derivative” does not include listed / exchange trades derivatives.  The final sentence of paragraph 3 states “An institution shall consider whether trades or securities it holds as collateral are concentrated in a particular counterparty and if that counterparty exited the market precipitously whether the institution would be able to replace those trades or securities.” Is this is a clarification of 3(b) meaning that the reference to “replace those trades” would be in relation to OTC derivatives? Or alternatively is the reference to “replace those trades” broader than OTC derivatives?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7229
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 31/01/2025

Risk weighting attributed to gold in the form of a commodity

Is the definition of “gold bullion”, as amended by Regulation (EU) 2024/1623, more restrictive than the definition previously set forth in the Regulation (EU) No 575/2013 (CRR), or this new definition shall be interpreted applying the clarification provided by the EBA in the Q&A 2016_3011?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7228
  • Topic: Credit risk
  • Date of submission:

Calculation of GAR - Template 8 of ESG Templates Pillar 3

How should we correctly compute the GAR (%) stock and flow?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR
  • ID: 2024_7227
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 27/03/2025

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

Reporting of customer portfolios managed on a discretionary basis

According to Annex V, Part 2, paragraph 285 (a) of Commission Implementing Regulation (EU) 2021/451 (ITS): '‘'Asset management’ shall refer to assets belonging directly to the customers, for which the institution is providing management.” Since these assets belong to the customers, they are generally not recognized in the balance sheet of the credit institution. It is not clear however if the cash deposited by customers that the institution manages on a discretionary basis should be recognized as a liability. Additionally, if this account would have a negative balance, an asset might be recognized. 

  • 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: 2024_7224
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2025

Definition and scope of Asset Under Management

Are assets for which the investment firm provides generic advice services (outside of the MIFID authorisation scope)  to be included in the K-AUM calculation?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7223
  • Topic: K-factor requirements
  • Date of submission:
  • Published as final Q&A: 14/03/2025

FINREP Group Structure Template 40.02

For entities which are consolidated as part of the Group, where a subsidiary of the economic group has legal ownership over these entities, but the group has no legal ownership over that subsidiary. What data should be reported in FINREP template F 40.02?

  • 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: 2024_7222
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 20/12/2024

Consistency of treatment between the technical guarantees that are subject to the Pillar 2 requirement (Supervisory Expectation of the ECB) and the technical guarantees that are subject to the Pillar 1 requirement (Regulation EU 2019/630).

Should the exemption of technical guarantees from the backstop calculation subject to the Pillar 2 requirement) be extended to the technical guarantees subject to the Pillar 1 requirement?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7221
  • Topic: Supervisory review and evaluation (SREP) and Pillar 2
  • Date of submission:
  • Published as Rejected Q&A: 20/11/2024

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:

Clarification of allocation of cash flows from floating rate instruments with amortizing principal for evaluating interest rate risk in the banking book using the standardised methodology

How should cash flows from floating rate instruments with amortizing principal be allocated into repricing time buckets under the standardised methodology for evaluating interest rate risk in the non-trading book?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7218
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 21/02/2025

contrôle sur remise IRBB

voici les éléments concernant nos interrogations sur le J 07.00.   Dans ce dernier, nous sommes tenus de ventiler les "notional repricing cash flows" selon les buckets de repricing. Dans l'Annex II (en PJ), il est fait référence  aux RTS on SA (également en PJ) pour définir ces "notional repricing cash flows"  L'article 1.1(2) traitant de la définition de "repricing date", on trouve dans l'article 1.1(1)  En d'autres termes, cet indicateur s'entend comme la somme du capital échu ou ayant refixé, plus intérêts à taux connu.   Or, si l'on s'en réfère aux contrôles v22322_m et v22323_m dans les validation rules (également en PJ) fourni par l'EBA, le notionnel doit être supérieur ou égal à la somme des flux, ce qui est impossible si l'on inclut les intérêts.   Il y a soit un problème dans la définition de "notional repricing cash flow", soit dans celle du contrôle mais en l'état, les 2 ne peuvent coexister.  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2015/585 - RTS for the specification of margin periods of risk
  • ID: 2024_7217
  • Topic: Supervisory reporting - IRRBB
  • Date of submission:
  • Published as Rejected Q&A: 28/04/2025

Supervisory Factor for Credit Derivatives with underlying securitization for SA-CCR

The supervisory factor for the credit risk category add-on is to be assigned based on the rating assigned to the issuer of the underlying credit derivative.For securitisations, should the rating of the SPV issuing the various tranches be used or can the rating of the tranche be used? If the SPV is not rated but the tranches are, should the exposure be considered unrated?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7216
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2025

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:

a) Disclosure of Items in Transit balance in FINREP Table 01.01 {F01.01, c0010 (r0020 or r0183 or r0360)} b) EBA_v5013 (Type - Error): [F 05.01, F 01.01] Sum of Loans & Advances across Industry ({{F 05.01, r0080, (c0010, c0020, c0030, c0040, c0050, c0060)}}) Should be equal to Sum of Cash at Central Banks and Loans & Advances in Balance Sheet ({{F 01.01, c0010, (r0030, r0040, r0099, r0130, r0144, r0174, r0178, r0183, r0233, r0237)}})

1) Disclosure of items in transit balance in FINREP Template F 01.01 {F01.01, c0010 (r0020 or r0183 or r0360)} Please clarify where the items in transit balances should be reported in Template F01.01 out of the following? a) Other Assets (c0010, r0360) b) Loans & advances at amortised cost (c0010, r0183)  c) Cash on hand (c0010, r0020). 2) EBA_v5013 (Type - Error): [F 05.01, F 01.01] sum of Loans & Advances across Industry ({{F 05.01, r0080, (c0010, c0020, c0030, c0040, c0050, c0060)}}) should be equal to sum of Cash at Central Banks and Loans & Advances in Balance Sheet ({{F 01.01, c0010, (r0030, r0040, r0099, r0130, r0144, r0174, r0178, r0183, r0233, r0237)}})

  • 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: 2024_7212
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 20/12/2024

Calculation of the EAD in BA-CVA

To compute the BA-CVA, on netting sets for which an institution computes the EAD using its IMM model, can you confirm that the EAD calculated using current market data should be used?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7211
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 06/11/2024

Own funds requirement for asset-referenced token issuers

Are issuers of asset-referenced tokens, who are exempt from authorization requirement pursuant to Article 16(2) of MiCAR, subject to the own funds requirement pursuant to Article 35(1) of MiCAR?

  • Legal act: Regulation (EU) No 2023/1114 (MiCAR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7210
  • Topic: Own Funds (MiCAR)
  • Date of submission:
  • Published as Rejected Q&A: 21/11/2024