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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

Intermediate Parent Undertaking

Which authority is competent for allowing institutions to have two IPUs under Article 21b(2) CRD?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6088
  • Topic: Other issues
  • Date of submission:

Residual contractual maturity date applicable to commercial paper issued under a commercial paper program with a firm underwriting commitment to rollover

What should be the residual contractual maturity applicable to commercial paper issued under a commercial paper program with a firm underwriting commitment to rollover?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6087
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 22/12/2022

ASF applicable to payables (accruals) in the NSFR

What should be the available stable funding factor applicable to payables (accruals)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6085
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 30/09/2022

Capacity of a CSD-banking service provider to convert into cash on a same-day basis collateral or investments through prearranged and highly reliable funding arrangements

What is the meaning of “same day basis” and the settlement period linked to it in Article 10(2)(f) of Regulation (EU) 2017/390?   Furthermore, in view of cut-off times of prearranged and highly reliable funding arrangements including committed repo lines, does the notion ‘same-day basis’ strictly require the conversion of collateral or investments into cash on the same day, or is it sufficient that a CSD-banking service provider has the capacity to start the conversion process on the same day?

  • Legal act: Regulation (EU) No 909/2014 (CSDR) - only RTS 2017/390
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2017/390 - RTS on prudential requirements of CSDs (CSDR-related)
  • ID: 2021_6083
  • Topic: Market infrastructures
  • Date of submission:
  • Published as final Q&A: 06/01/2023

Definition of parent undertaking for the purposes of CRR

Can an undertaking for which Directive 2013/34/EU (the “Accounting Directive”) does not apply be considered a parent undertaking for the purposes of CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6082
  • Topic: Own funds
  • Date of submission:

Deduction of software assets from Common Equity Tier 1 capital (hereinafter CET1) for investment firms of Class 2 and Class 3

Is it appropriate to apply Article 13a of Commission Delegated Regulation (EU) No 241/2014, amended by Commission Delegated Regulation (EU) 2020/2176, regarding the deduction of software assets from CET1 to investment firms of Class 2 and Class 3, taking into account that the mentioned investment firms are not subject to the application of provisions established in Art. 113(5) and Art. 156 of the CRR, i.e. to apply 100% of risk weight to the portion of the carrying amount of software that is not deducted from CET1?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions
  • ID: 2021_6079
  • Topic: Own funds
  • Date of submission:

Information on the host member State in which Third Party Providers (TPPs) provide services

If a payment institution, in the specific form present in the EBA register under PSD2, presents an EU passport, does this mean that the Third Party Provider (TPP) is authorised to operate for the services indicated in all EU countries?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2019/411 - RTS on EBA register under PSD2
  • ID: 2021_6078
  • Topic: Central register of the EBA
  • Date of submission:
  • Published as final Q&A: 14/10/2022

Confirmation of Funds (CoF) request by a PISP in case of batch processing system

With respect to confirmation of funds request made by a Payment Initiation Service Provider (PISP), in the event that the Account Servicing Payment Service Providers (ASPSP) makes use of a batch processing system, should the ASPSP take into account batches that are in the queue waiting to be processed at the point when the fund confirmation request is made?

  • 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: 2021_6077
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 17/12/2021

Calculation of the exposure value of regular-way purchases and sales awaiting settlement

Should a Regular Way operation (under settlement date accounting and DVP) that doesn't have an underlying security but mere currency be reported in row 188? In other words, is the presence of a security mandatory to qualify what has to be reported in rows 188/189?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6066
  • Topic: Leverage ratio
  • Date of submission:
  • Published as Rejected Q&A: 26/01/2023

Calculation of exposure-weighted average PD (column 0050 in C08.03)

It is not clear from the instructions how the exposure-weighted average PD in template C08.03 (Breakdown by PD ranges) should be calculated.

  • 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
  • ID: 2021_6062
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 31/03/2023

Treatment of an institution’s investments into EU AIF managed by a non-EU AIFM and into closed-ended CIUs

Should not the investment of an institution into a closed-ended CIU which has been marketed in accordance with Article 42 of AIFMD, but is not marketed anymore due to the end of its marketing phase, remain eligible to apply the look-through to the underlying exposures of the CIU, provided the other relevant conditions for looking-through continue to be met?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6057
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/11/2022

Asset encumbrance in the NSFR

How to determine the residual maturity of the encumbrance in a cover pool if it derives from covered bonds with different maturity?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6055
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 30/09/2022

Legitimacy of the suspension of the accounts of one or more users by the owner of a digital platform, upon request of an obliged entity, due to suspicious transactions executed on the digital platform.

If a payment institution detects that several suspicious payment transactions have been executed or are to be executed on a digital platform and requests the owner of such platform to suspend the accounts of the users who have initiated such suspicious transactions, should the owner of the digital platform be exonerated for any liability due to the suspension of such users’ accounts?

  • Legal act: Directive (EU) 2015/849 (AMLD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6054
  • Topic: Suspicious Transaction Reporting
  • Date of submission:

Calculation of past due days

a. Shoud materiality threshold be used in a Template 7.01? b. If in a Template 7.01 materiality threshold shouldn't be used, can we have for same exposure differently reported past due time buckets in templates 7.01 and 18.00?

  • 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
  • ID: 2021_6050
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/02/2022

PISP obligations to conduct CDD

In the case where the Payment Initiation Service Provider (PISP) has a business relationship as defined under Article 3(13) of Directive (EU) 2015/849 (AMLD) with the payee, and not with the payer, would it still be considered an occasional transaction for the payer, as the service is provided as a single transaction for the initiation of a payment order from the account that belongs to the payer? 

  • Legal act: Directive (EU) 2015/849 (AMLD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/02 - Guidelines on customer due diligence and the factors institutions should consider when assessing the ML /TF risk associated with individual business relationships and occasional transactions under Articles 17 and 18(4) of AMLD
  • ID: 2021_6048
  • Topic: Customer Due Diligence
  • Date of submission:
  • Published as final Q&A: 17/03/2023

Validation Rules v6205_m and v6206 in respect of portfolios with only Unfunded Credit Protection

How the two blocking Validation Rules v6205_m and v6206_m in current DPM, applicable to Supervisory Benchmarking reporting, shall be managed in light of the regulatory provisions of Article 158(5) of Regulation EU 575-2013 (CRR) allowing portfolios to have Expected Loss equal to zero and PD, LGD, EAD all greater than zero?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2021_6047
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as Rejected Q&A: 28/03/2022

Calculation of NPV loss in case of (internal) refinancing

Which NPV loss should be taken in order to calculate the NPV loss if the 1% threshold is breached and the forborne loan contract should be placed in default?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/07 - Guidelines on the application of the definition of default under Article 178 CRR
  • ID: 2021_6045
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022