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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

Collateral haircuts for third-country equivalent PSE-RGLA’s

For the purposes of Article 197(2)(a) and (b) CRR, should the references to PSEs and RGLAs in Articles 115(2) and 116(4) CRR be interpreted as encompassing the third-country equivalent entities referred to in Articles 115(4) and 116(5) CRR, such that debt securities issued by those entities qualify for the treatment provided under Article 197(1)(b) CRR? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7989
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Use of the EBA’s aggregated loss data for “All national markets outside the Union” for the purposes of Articles 125 and 126 CRR.

Does the row “All national markets outside the Union” in the EBA publication Immovable-property loss data, Q4 2025 constitute a publication of loss-rate data that may be relied upon, in respect of immovable property situated in Switzerland, for the purposes of the loss-rate requirements referred to in Article 125(3), second subparagraph, and Article 126(3), second subparagraph, CRR? In particular, may an institution use the losses and exposure amounts reported in that aggregated row to assess whether the applicable loss-rate thresholds are met for exposures secured by residential or commercial immovable property situated in Switzerland, notwithstanding that Switzerland is not presented as a separate national immovable property market?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7980
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Treatment of the secured portion of defaulted IPRE exposures under the Standardised Approach

Under the Standardised Approach for credit risk, Article 127(3) CRR states that: "The exposure value remaining after specific credit risk adjustments of non-IPRE exposures secured by residential property or commercial immovable property in accordance with Articles 125 and 126, respectively, shall be assigned a risk weight of 100 % if a default has occurred in accordance with Article 178." Articles 125(2) and 126(2) establish dedicated treatments for income-producing real estate (IPRE) exposures through ETV-based risk-weight buckets. Following the CRR3 amendments, Article 127(3) explicitly refers only to non-IPRE exposures and does not specify the treatment of the secured portion of IPRE exposures after default.  Could the EBA clarify the prudential treatment of a defaulted IPRE exposure that satisfies all requirements of Article 124 and is secured by residential property or commercial immovable property? In particular: Should the secured portion of a defaulted IPRE exposure continue to be risk weighted according to the ETV buckets in Article 125(2) or Article 126(2), as applicable? Alternatively, should the secured portion of a defaulted IPRE exposure be reported in the exposure class "Exposures in default" and be assigned a risk weight of 100%, analogously to the treatment laid down in Article 127(3) for non-IPRE exposures, despite IPRE exposures not being explicitly referred to in that provision   If neither of the above approaches is correct, what is the appropriate risk-weight treatment and COREP reporting treatment for the secured portion of defaulted IPRE exposures under the Standardised Approach? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7979
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Application of the SME supporting factor to exposures financing private purposes following CRR III

Following the amendments introduced by Regulation (EU) 2024/1623 (CRR III), Article 501(2)(b) CRR defines an SME by reference to Article 5, point (9), CRR rather than to Commission Recommendation 2003/361/EC. Where the obligor is a natural person who carries out an economic activity and meets the turnover criterion in Article 5, point (9), should SME status be determined once at obligor level — so that the adjustment under Article 501(1) applies to all non-defaulted exposures to that obligor meeting Article 501(2)(a) — or should it continue to be assessed exposure by exposure by reference to the purpose of the individual financing, as set out in EBA Q&A 2021_6301?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7971
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

National competent authorities power to increase the quantity of ARTs and EMTS issuers' own funds or reserve assets in relation to Article 45(4)

Does Article 45(4) of Regulation (EU) 2023/1114 (MiCA) confer on national competent authorities or the EBA the power to require an ART or EMT issuer to increase the quantity of its own funds or reserve assets beyond the 1:1 backing established under Articles 36–38 of MiCA, or is the scope of Article 45(4) confined to requiring improvements to the composition, maturity and liquidity profile of reserve assets? More broadly, are the reserve and capital requirements that may be imposed on ART and EMT issuers under MiCA Level 1 capped by the mechanisms expressly provided for therein — in particular the bounded own-funds add-on mechanism of Article 35(5) following stress tests — such that national competent authorities or the EBA do not have discretion under Article 45(4) to impose open-ended or permanent structural overcollateralization or additional capital requirements beyond what MiCA Level 1 has expressly foreseen?

  • Legal act: Regulation (EU) No 2023/1114 (MiCAR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7968
  • Topic: Authorisation of issuers of ARTs and EMTs (MiCAR)
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

CVA exemptions: marginal impact of reintegration

Annex II of the ITS requires to show the marginal impact of reintegration of CVA exemptions, separately for each exemption. it defines the marginal impact as "the difference, expressed in absolute amount, between the relevant metric for the scope of transactions referred to in row 0010 after reintegrating the exemption, and the relevant metric for the scope of transactions referred to in row 0010".  This statement may in our opinion be interpreted in two different ways: For each of the 7 exemptions and for the whole portfolio including the exemptions, institutions are required to calculate the cva risk charge for the non-exempted portfolio + the relevant exemption separately and report the difference to the cva risk charge calculated for the non-exempted portfolio. This requires 8 separate calculations and the marginal impact of individual exemptions will be accurate. However, the marginal impact for the individual exemptions will not add up to the marginal impact for the whole portfolio. Institutions are required to calculate the difference of the cva risk charge calculated for the whole portfolio to the cva risk charge calculated for the non-exempted portfolio. This difference will be split up for the 7 exemptions using the contributions on counterparty level already calculated for the whole portfolio. This requires 1 separate calculation and the marginal impact for individual exemptions will add up to the marginal impact for the whole portfolio. However, the marginal impact of each individual exemption will be only approximate (i.e. scaled by counterparty contributions). Question: are institution allowed to use method (2)?

  • 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: 2026_7941
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Classification of spread components of floating-rate instruments for contractual repricing reports

How should institutions classify the fixed spread component of a floating-rate instrument when reporting IRRBB repricing cash flows? Article 7 of Commission Implementing Regulation (EU) 2024/857 requires institutions to allocate the spread components of floating-rate instruments "up to the final contractual maturity, irrespective of any repricing of the non-amortised principal". However, Annex V, Section 3, states that the distinction between fixed-rate and floating-rate instruments is to be applied at instrument level. Under this definition, an instrument whose interest payments are contractually linked to an external benchmark is classified as a floating-rate instrument. In practice, two alternative interpretations have emerged: Cash-flow level interpretation: the fixed spread component of a floating-rate instrument is treated as a fixed-rate cash flow extending until contractual maturity and therefore reported within the fixed-rate section of the repricing templates. Instrument level interpretation: the spread component remains associated with the floating-rate instrument and is therefore reported within the floating-rate section, even though Article 7(c) requires the spread cash flows to be allocated up to final maturity. Should institutions report the spread components of floating-rate instruments in the fixed-rate section because they are allocated until final contractual maturity under Article 7(c), or should they remain in the floating-rate section because the fixed/floating classification applies at instrument level according to Annex V?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
  • ID: 2026_7940
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Treatment of bank guarantees posted by clearing members as initial margin for the purpose of NICA in the CCP hypothetical capital (KCCP) calculation under Article 50a of EMIR

When a CCP calculates the hypothetical capital requirement (KCCP) pursuant to Articles 50a-50b of Regulation (EU) No 648/2012 (EMIR), as amended by Regulation (EU) 2019/876, applying the SA-CCR methodology set out in Part Three, Title II, Chapter 6, Section 3 of CRR, can bank guarantees provided by that clearing member be recognised as part of the collateral in the NICA term, provided that they are contractually pledged to the CCP and can be drawn upon in the event of the clearing member’s default? If the answer to Question 1 is negative and Article 276(1)(a) and (b) of CRR should be applied in full such that the only collateral eligible for inclusion in the NICA is that which qualifies as eligible financial collateral under Article 197 CRR (and Article 299 CRR for netting sets belonging entirely to the trading book), should a CCP assign a value of zero to bank guarantees posted by clearing members as initial margin when computing the Replacement Cost and the PFE multiplier? Or is there an alternative treatment available under the SA-CCR framework that would allow a CCP to partially or fully reflect the risk-mitigating effect of such guarantees in the EAD calculation?

  • Legal act: Regulation (EU) No 648/2012 (EMIR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7937
  • Topic: Market infrastructures
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Methodology for calculating the scenarios referred to in Article 25(2), (3), and (4), as well as point 5(a), (b), and (c) of the Annex to the Regulation.

Our Bank as another non-listed institution, as part of the CRR Regulation, is required to apply the "standardized approach" for interest rate risk, as defined in Regulation 2024/857. Banks subject to the simplified standardized methodology apply, by way of derogation from Article 8(9), the pass-through rate specified in point 5(a), 5(b), and 5(c) of the Annex. Our Bank, as another non-listed institution, should independently calculate the pass-through rate, taking into account the Bank's historical data for the base scenario and scenarios predicting a decrease and an increase in short-term interest rates. Currently, the Bank applies the pass-through rate from points 5a, 5b, and 5c of the Annex to the Regulation. Since the UKNF has issued a recommendation that the Bank independently determine the pass-through rate, please provide the methodology for calculating the scenarios referred to in Article 25(2), (3), and (4), as well as point 5(a), (b), and (c) of the Annex to the Regulation.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/857 - RTS on the IRRBB standardised approach
  • ID: 2026_7933
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 11/08/2026

Risk weights assignment to IPRE exposures secured by many properties

Articles 125 and 126 paragraph 2 Regulation (EU) No 575/2013 (CRR) specify the rules for risk weights assignment to IPRE exposures, respectively secured by residential and commercial properties. However, these regulations don’t clarify how risk weights should be assigned to IPRE exposure when it’s secured by both residential and commercial property – especially when one property is IPRE (income producing property) and the second one is non-IPRE (the residential property, let’s assume that this is the flat of a counterparty). 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7923
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 06/07/2026

Clarification of ETV calculation for mortgages securing more than one exposure

Article 124 paragraph 6 Regulation (EU) No 575/2013 (CRR) specifies the calculation of ETV for IPRE exposures. In order to calculate ETV, the gross value of an exposure should be divided by the value of property. Additionally, this article clarifies that: “For the purposes of the first subparagraph, point (a), where an institution has more than one exposure secured by the same immovable property and those exposures are secured by liens on that immovable property that are sequential in ranking order without any lien held by a third party ranking in-between, the exposures shall be treated as a single combined exposure and the gross exposure amounts for the individual exposures shall be summed up to calculate the gross exposure amount for the single combined exposure.” Our question refers to calculation ETV for joint mortgages – so the mortgage which secures more than one exposures and additionally these exposures may have other mortgages assigned. Based on the above, it’s clear that numerator should include the gross value of all exposures secured by this joint mortgage. Nevertheless, it’s unclear which value should be used in the denominator of ETV in the real life example described below.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7922
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 06/07/2026

Definition of "main business" under CRR

How are banks to interpret the concept of "main business" in Article 411(1) of Regulation (EU) No 575/2013 (CRR), read in conjunction with Annex I of Directive 2013/36/EU and Article 3(9) of Commission Delegated Regulation (EU) 2015/61? In particular: can an entity be considered to perform Annex I CRD activities as its "main business" within the meaning of Article 411(1) CRR if: there is an absence of any third-party commercial activity i.e. entity does not offer financial services to any external party for commercial consideration nature of the entity’s operations is ancillary to the group and it exists solely as an instrument of the group's non-financial operations with no independent commercial purpose

  • 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: 2026_7921
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 06/07/2026

Reporting obligations under Article 3 of the CIR

Whether, and to what extent, will the reporting obligations concerning Relevant Legal Entities (RLEs) under Article 3 of the CIR also apply where a recently acquired RLE is expected, with a high degree of certainty, to cease to exist as a legal entity prior to the adoption of the resolution plan as a result of a legal merger. Additionally, how should this acquired entity be treated for the purposes of resolution planning and related reporting obligations during the interim period between its acquisition and its absorption through merger? We wonder if resolution authorities (RAs) may waive the reporting obligations for this acquired entity for the first reporting cycle after acquisition. Against this background, does the framework require or allow a reclassification of the acquired entity (which used to be a Liquidation entity before acquisition with no reporting obligations) as an RLE immediately upon acquisition, implying inclusion in the group’s resolution plan and submission of the applicable reporting templates? Alternatively, may the acquired entity continue to be treated as a liquidation entity until the legal merger is completed, with its status and standalone reporting obligations remaining unchanged during the interim period? Clarification is sought on whether, in the context of M&A transactions, resolution authorities are expected to adjust the entity’s classification upon acquisition, or whether they may maintain the pre-acquisition status until legal integration is finalised.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7918
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Treatment of the Right Way Risk in Call Warrant

Is a call warrant issued by the counterparty  that is also the issuer of the underlying shares exempt from counterparty credit risk requirements?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7911
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Validation Rule RRCOROF_V903610_H_C0030

Could you please clarify the validation rules newly introduced or reactivated in template C34.03 within COROFI and COROFC as of 31 March 2026? These rules require that the totals for Number of Transactions (RRCOROF_V903610_H_C0030_S0001), Nominal Amount (RRCOROF_V903610_H_C0040_S0001), Positive Market Value (RRCOROF_V903610_H_C0050_S0001 ) and Negative Market Value (RRCOROF_V903610_H_C0060_S0001)  and Add-on (RRCOROF_V903610_H_C0070_S0001) equal the sum of the respective risk categories (Interest Rate Risk, Foreign Exchange Risk, Credit Risk, Equity Risk, Commodities Risk, Other).     

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7910
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 31/08/2026

Incorrect Quality Control check EGDQ_0764 for Annex I, INSTRUCTIONS FOR REPORTING ON SPECIFIC REQUIREMENTS FOR MARKET RISK, Template ({C90.00,r0010,c0080})

Data Quality ID EGDQ_0764 should be disabled as Total Assets reported in FRTB ({C90.00,r0010,c0080}) does not correspond to the amount reported in FINREP ({F01.01,r0380,c0010})

  • 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: 2026_7906
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Template F 13.2.1.c VariableID 433471 and 433464

Following the most recent update to the FINREP validation framework under Reporting Framework 4.2., a new data point categorization has been introduced affecting template F 13.2.1.c, specifically Variable IDs 433471 and 433464. We would appreciate confirmation as to whether this data point categorization has been correctly defined and, if so, clarification on the prudential reporting rationale underlying it. Our concern is that the validation may not be conceptually appropriate in all cases, as not all additions of foreclosed assets necessarily qualify as non-current assets held for sale.

  • 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: 2026_7904
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Exemption from deduction of Equity Holdings in an insurance company from CET1

Institution “A” currently applies the exemption provided under Article 471 CRR, whereby it does not deduct from its own funds a qualifying shareholding held in Insurance Undertaking “C” for an amount not exceeding the amount held in CET1 instruments issued by that Insurance Undertaking as of December 31, 2012 . Following the completion of a merger by absorption between Institution “A” and Institution “B” – as a result of which Institution “B”, as surviving entity, becomes the direct holder of the shareholding in Insurance Undertaking “C” by virtue of universal succession – is Institution “B” entitled to continue to apply the exemption under Article 471 CRR, as previously applied by Institution “A” in respect of such shareholding? Upon completion of the merger mentioned in question 1 above, would Institution “B” be entitled to apply the exemption under Article 471 CRR on a consolidated basis in case its direct shareholding in Insurance Undertaking “C” is transferred (as a result of a partial de-merger) to its wholly owned subsidiary Institution “D”, given that the shareholding in Insurance Undertaking “C” would in any event be held within the consolidation perimeter of Institution “B”? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7903
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 06/07/2026

Requirement for a consolidated ICARA process under Directive (EU) 2019/2034

Does Directive (EU) 2019/2034 require investment firms that are subject to prudential consolidation under Article 7 IFR to prepare, maintain and document an ICARA process on a consolidated basis? In particular, does Article 25(4) IFD impose an obligation to perform the ICARA at consolidated level, or does it merely extend the application of Part Three without creating a standalone consolidated‑ICARA requirement?

  • Legal act: Directive (EU) 2019/2034 (IFD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7891
  • Topic: Supervision of investment firm groups
  • Date of submission:
  • Published as Rejected Q&A: 15/06/2026

Application and interpretation of the 50% / 80% weighting of positive changes under IRRBB SOT

How should Article 4(l) of the RTS on Supervisory Outlier Tests be interpreted in relation to the weighting of positive changes, in particular regarding: Whether the 80% weighting factor and associated cap should apply to EUR, given that EUR is not an ERM II currency. Whether the reference to “absolute value of negative changes in EUR or ERM II currencies” when calculating the cap should be interpreted as a sum of negative changes across all currencies or as a minimum reference between EUR and ERM II currency buckets. Whether the weighting of positive changes should be applied at the individual risk level or at an aggregated level?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7886
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission: