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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.

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List of Q&A's

C08.07: credit risk only?

Is report C08.07 limited to Credit Risk only, or is Counterparty Credit Risk included in the scope?

  • 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: 2022_6441
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2022

Preferential risk weight for exposures to central governments and central banks under Article 114(4) of CRR

Does Article 114(4) of CRR apply to both on-balance sheet and off-balance sheet liabilities (including the forward leg of an FX swap) in the same domestic currency and at least the same amount as the exposure to the central government or central bank (on- or off- balance sheet exposures)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6439
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/11/2022

Annex VI - Agentes/distributors

Please clarify whether under Directive 2015/2366, in the exchange of notifications between NCAs, Annex VI of the Commission Delegated Regulation (EU) 2017/2055 should be sent concerning each new agent/distributor or only for the first agent/distributor acting on behalf of a payment/e-money institution.

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2017/2055 - RTS on passporting under PSD2
  • ID: 2022_6437
  • Topic: Passporting
  • Date of submission:
  • Published as final Q&A: 14/10/2022

Application of Articles 52 and 54 of Regulation No. 575/2013 (CRR) at consolidated level

How should the consolidated level of AT1 instruments where the issuer is a 100% fully owned subsidiary of an EU institution where the subsidiary is established in a third country and has not been designated in accordance with Article 12 of Directive 2014/59/EU (BRRD) as part of a resolution group the resolution entity of which is established in the Union be treated?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6436
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 11/11/2022

C 91.00: Relevant scenario for own funds requirements

Could you please indicate how Article 325h(4) CRR should be understood, in order to fill in information in template C 91.00? '4. The own funds requirement under the sensitivities-based method shall be the highest of the three scenario-specific own funds requirements referred to in paragraph 3.' It would make sense to select the most critical scenario and apply this one for all risks, without changing scenario from one risk to another, could you confirm?   

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/453 - ITS with regard to the specific reporting requirements for market risk
  • ID: 2022_6435
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 28/10/2022

Floors in calculation of RWA- and RWA --

For the purpose of Template C103 institutions shall report RWA- and RWA--. according to the corresponding instructions (Annex IV), RWA- and RWA-- result from the application of PD- and PD-- (instead of the institution’s PD values). For this purpose, shall regulatory PD-floors as defined in Art. 160 (1) and 163 (1) CRR be applied?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
  • ID: 2022_6434
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as Rejected Q&A: 26/07/2022

Reporting of guarantees/non-financial collaterals in providing further credit risk mitigation for derivatives and SFTs in the credit risk templates C 07.00 / C 08.01

Following the logic of the C07.00/C08.01-templates (with DPM 3.0), probable guarantees/non-financial collaterals of derivatives and securities financing transactions (SFTs) won't be captured in the first part of the form (C07.00: columns 0010-0200/ C08.01: columns 0020-0110) even if available. However, starting with the reporting of the exposure value of the derivatives and SFTs (C07.00: column 0200/ C08.01: column 0110) the guarantees/non-financial collaterals will be considered in the second part of the template (starting with the exposure value-column) as its risk-mitigating effects should flow into the RWA calculation. Does the above-mentioned logic follow the reporting requirements of the C07.00/C08.01 templates under DPM 3.0?

  • 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: 2022_6433
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 29/06/2023

Original maturity of credit lines until further notice

For risk classification as off-balance sheet item according to Annex I CRR, is the original maturity longer than one year where non-retail credit lines until further notice (i.e. no fixed maturity) may be cancelled with 3 months advance notification period and even immediately in case the borrower becoming delinquent or declaring bankruptcy?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6432
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 22/12/2022

Calculation of goodwill included in the valuation of significant investments in insurance undertakings

A. For the purposes of a deduction under Article 36(1)(b) CRR as per Article 37(b), should the goodwill (Article 4(1) no. 113 and 115 CRR) included in the valuation of significant investments calculated excluding goodwill booked under an insurance subsidiary given that this goodwill is not included in the valuation of a significant investment of the bank (i.e. goodwill not included in the prudential consolidation as per Articles 1, 11, 18 and 24 of CRR and EBA RTS on the methods of prudential consolidation)?  B. Can you confirm that the goodwill booked under an insurance subsidiary (which is excluded from the valuation of significant investments as per prudential consolidation) should be treated as part of the equity exposure of the bank to the insurance subsidiary and this be risk weighted as per Article 49(1) and Articles 133 or 155 (depending on Standardized or Advanced IRB method)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6431
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 26/07/2022

FINREP V5686_s: for the rows (080;150) Col. 050 > 0

EBA V5686_s signage validation requires positive amounts in column 050 (Macro Hedges - Hedged Items in Portfolio Hedge of Interest Rate Risk). Please can you advise on whether FINREP permits negative amounts in column 050 for rows 080 and 0150?

  • 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: 2022_6430
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 10/03/2023

Reporting requirement of C34.01

Are all institutions with CCR exposures required to complete the template C 34.01, or only those institutions that use the methods set out in Section 4 or 5 of Chapter 6 of Title II of Part Three CRR?

  • 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: 2022_6429
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2022

Reporting of critical external providers in template Z 08.00

Does a critical external / third-party provider to a service provider which is not indicated as relevant and listed in template Z 01.00 have to be reported in template Z 08.00?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans
  • ID: 2022_6428
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 22/02/2023

Business line mapping of ancillary activities

For the purposes of assigning banking business activities to a determined business line, in the case that an institution carries out an activity that supports its retail business of deposits acceptance, considering that the institution has neither a separate organizational unit nor a specific profit and loss account for this supportive activity, should it be allocated to the “retail banking” business line? On the other hand, if such activity is carried out by the institution in a separate organizational unit as regards its internal management accounting statements (not necessarily included in a different legal entity), should it be considered as an activity consisting on the placing of financial instruments (as it is calculated from the management profit and loss account) , and thus be mapped into the “retail brokerage” business line?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6427
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 26/07/2022

Operational Risk - Refund of interest and fees

Do we have to report refunds to customers in combination with incorrectly overchared interest/fee in COREP 17.01? And if so, in which of the following situations:  1. refund by the bank within less than 5 days  2. refund by the bank within a quarter (before the quarterly financial statement is prepared)  3. refund by the bank within one year (before the annual balance sheet and income statement are prepared)  4. refund by the bank after several years  The timing of the outflow of the refund to the customer depends in each case on the time at which the error is identified.

  • 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: 2022_6426
  • Topic: Operational risk
  • Date of submission:
  • Published as final Q&A: 31/03/2023

Allocating exposures into the correct vintage buckets of the „NPL-backstop“ acc. to Art. 47c CRR applying Art. 469a CRR

For exposures classified as non-performing prior to 26 April 2019 and not exempt from the deductions from CET1 items for non-performing exposures acc. to Art. 36 (1)(m) applying the second subparagraph of Art. 469a CRR, which date should be considered when allocating those exposures into the vintage buckets of the “NPL-backstop” in COREP template C 35.01 to C 35.03 in order to determine the applicable amount of insufficient coverage for non-performing exposures acc. Art. 36 (1)(m) in conjunction with Art. 47c CRR: Is it the date on which the exposures were originally classified as non- performing, as it is with purchased non-performing exposures (see EBA ITS regarding C 35.01 c0010 - c0100) – in the example above a date prior to 26 April 2019? Or is it the date on which the criteria of the second subparagraph Art. 469a CRR (terms and conditions of the exposure - originated prior to 26 April 2019 - were modified by the institution in a way that increases the institution’s exposure to the obligor) were fulfilled and therefore the exposure shall be considered as having been originated on the date when the modification applies?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6425
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 22/03/2024

The potential future exposure of a netting set with bilaterally exchanged collateral

The potential future exposure of a netting set with clients for which collateral is exchanged bilaterally may be decreased to 42%. Is it applicable only if the investment firm is the recepient of the collateral (initial and variation margin) or it can be also applied if the investment firm is the collateral provider.

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on reporting and disclosure requirements for investment firms
  • ID: 2022_6424
  • Topic: K-factor requirements
  • Date of submission:
  • Published as Rejected Q&A: 09/09/2022

Concentration risk and own risk hedging

As per IFR article 36 paragraph 1 investment firm shall calculate exposure value with regard to a client or group of connected clients for the purposes of concentration risk as the exposure value of contracts and transactions referred to in Article 25(1) with the client in question, calculated in the manner laid down in Article 27. The question is whether the concentration risk should be also calculated for financial counterparties (e.g. members of QCCP) who investment firms hedge their own risk with (hedging of positions arising from derivatives with their clients).

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on reporting and disclosure requirements for investment firms
  • ID: 2022_6423
  • Topic: Concentration risk
  • Date of submission:
  • Published as Rejected Q&A: 09/09/2022

Treatment of intragroup liabilities when one of the institutions is established in a country being a member of EEA and EFTA (i.e. non-EU Member State but EEA Member State)

Should, according to Article 5(1)(a) of Commission Delegated Regulation (EU) 2015/63, intragroup liabilities be deducted from the contribution base when one side of the transaction is an institution established in a country being a member of the EEA and EFTA (e.g. Norway)? If so, from which date such deductions shall be applied?

  • 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: 2022_6422
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as final Q&A: 22/03/2024

EMI's application of negative interest rates to its clients

Is an electronic money institution (EMI) allowed to apply negative interest rates to its clients (electronic money holders)?

  • Legal act: Directive 2009/110/EC (EMD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6421
  • Topic: Not applicable
  • Date of submission:

Is the RWA capped at EAD amount for IRBA exposures as suggested by SBP validation check v6210

SBP validation check v6210 is set as an error which prevents the reporting of exposures with RWA higher than 12,5xEAD.  Verification is sought to the legal rationale behind setting such a maximum RWA limit.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2022_6420
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as Rejected Q&A: 27/01/2023