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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

Incoherent formulae of the validation rule v90317_m

The control formula currently in place for column 0070 / row 0340 of template C16.02 does not seem aligned with your definition of this indicator. Could you clarify the expected logic?

  • 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_7862
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

Incoherent formulae of the validation rule v90316_m

The control formula currently in place for column 0070 / row 0310 of template C16.02 does not seem aligned with your definition of this indicator. Could you clarify the expected logic?

  • 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_7861
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

Incoherent formulae of the validation rule v90315_m

The control formula currently in place for column 0070 / row 0260 of template C16.02 does not seem aligned with your definition of this indicator. Could you clarify the expected logic?

  • 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_7860
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026

Sectoral classification of UK credit institutions

In the context of FINREP reporting, institutions are required to apply counterparty sector classifications as laid down in Annex V to Regulation (EU) No 680/2014. Following the withdrawal of the United Kingdom from the European Union, banks established in the UK are considered third‑country institutions and are no longer subject to the CRR/CRD framework. This has raised interpretative questions regarding their appropriate sectoral classification as counterparties in FINREP, in particular when ensuring consistency across EU supervisory reporting frameworks.    

  • 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_7843
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 03/07/2026

PILLAR 3 - form EU CMS2 mapping for row EU 7d: Categorised as subordinated debt exposures in SA

According to official mapping for row EU 7d: Categorised as subordinated debt exposures in SA, column "d" and "EU d" include form c07-qx2062 that refers to CRE IPRE OTHER. Is intention to see CRE IPRE OTHER , or maping should be changed and include subordinated debt exposures?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/14 - Guidelines on materiality, proprietary, confidentiality and disclosure frequency under Pillar 3
  • ID: 2026_7838
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 12/05/2026

PILLAR 3 - form EU CMS2 mapping for columns d and EU d

According to mapping, column “d” and “EU d” refers to c07 and c10. Some of cells in column “d” and “EU d” refers only to c10. Please, could you explain the reason to exclude c07 from some cells in column “d” and “EU d”?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/14 - Guidelines on materiality, proprietary, confidentiality and disclosure frequency under Pillar 3
  • ID: 2026_7837
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 12/05/2026

Proportional application of K-ASA under Article 19 IFR in non-discretionary custody models linked to the operation of an MTF

Under Article 19 of Regulation (EU) 2019/2033, is there any scope for a more proportionate or risk-sensitive application of K-ASA where an investment firm: operates an MTF as its core activity; safeguards assets strictly on behalf of clients as direct participant in a CSD; does not exercise discretion over those assets; does not assume balance-sheet risk in relation to them; is prohibited from trading on own account or lending client securities; does not exercise voting rights, represent clients at meetings, or administer decisions regarding the underlying instruments; and has demonstrably reduced operational risk through technological investment and streamlined post-trade processes? More specifically: can competent authorities take into account the specific characteristics of such a business model when assessing the prudential effect of K-ASA, or is the calculation strictly volume-based in all cases regardless of the underlying risk profile; and is there any scope to differentiate K-ASA treatment depending on the type of instruments safeguarded, in particular between equity and debt instruments, or depending on whether the custody client is itself a regulated financial institution such as an investment firm or a bank?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7836
  • Topic: K-factor requirements
  • Date of submission:
  • Published as Rejected Q&A: 11/05/2026

Scope of the exemption under Article 7(7) with respect to Level 1 assets referred to in Article 10(1)(c)

Do the requirements laid down in Articles 7(5) and 7(6) of Delegated Regulation (EU) 2015/61 apply to assets referred to in Article 10(1)(c)?

  • 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_7835
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 29/05/2026

Own funds requirement for entities authorized as Crypto Asset Service Provider (CASP), Electronic Money Institution (EMI) and Investment Firm (IF)

How should own funds requirements be determined for a legal entity authorised as a crypto-asset service provider (CASP) under Regulation (EU) 2023/1114 (MiCAR), as an electronic money institution (EMI) under Directive 2009/110/EC, and as an investment firm under Regulation (EU) 2019/2033 (IFR) and Directive (EU) 2019/2034 (IFD), in particular where certain crypto asset services – such as the transfer of crypto assets on behalf of clients – require a specific CASP authorization rather than a notification regime, and given the absence of explicit provisions governing the interaction between the two prudential frameworks?

  • Legal act: Regulation (EU) No 2023/1114 (MiCAR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7834
  • Topic: Own Funds (MiCAR)
  • Date of submission:
  • Published as Rejected Q&A: 29/05/2026

Shadow Banking Definition - Alternative Investment Funds

Where an entity qualifies as an alternative investment fund (“AIF”) for the purposes of Directive 2011/61/EU, but its constitutive documents do not explicitly prohibit loan origination or the purchase of third‑party lending exposures, should that entity be regarded as meeting the criterion in Article 1(c)(iii) of the relevant Delegated Regulation 2023/2779 (Identification of Shadow Banking) solely on the basis of what it is permitted to do, notwithstanding that it does not in practice carry out banking activities, as referred to in Article 394(2) CRR? In particular, should the assessment of whether an AIF falls within the definition of a shadow banking entity be determined by: the theoretical scope of permitted activities under its rules or instruments of incorporation, or the actual activities carried out by the AIF in the ordinary course of its business?

  • 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_7833
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 29/05/2026

Z08.0x The Service Identifier can only be set as an Integer instead of free text

Is it possible to apply the data type “free text” for the Service Identifier as specified in the Annex II IT Solution?

  • 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_7832
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Z08.04 The current key is incorrect in the ITS

Z08.04 The current key is incorrect in the ITS

  • 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_7831
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Geographical allocation of exposures arising from synthetic securitisations for the purposes of the Countercyclical Capital Buffer (CCB)

For synthetic securitisations where the originator: retains certain securitisation tranches (e.g. senior or mezzanine tranche), obtains funded credit protection for part of the junior risk, and obtains unfunded credit protection for another part of the junior risk, how should the geographical location of the originator’s remaining exposures be determined for purposes of CCB calculation? Specifically: Should all exposures arising from the securitisation—whether securitisation exposures or CRM‑transformed exposures—be allocated according to Article 4 of Delegated Regulation (EU) 1152/2014, based solely on the obligors of the underlying exposures?  Or should the following differentiated approach apply: retained securitisation exposures: allocation under Article 4 DelVO 1152/2014. funded protection: no remaining exposure → no CCB geographical allocation; unfunded protection: exposure is no longer a securitisation exposure but a CRM‑transformed credit exposure; Should the geographical allocation follow the logic of Q&A 2016_3050 (pre‑CRM exposure = underlying obligors = allocation according to Article 4 DelVO 1152/2014 the same as for the retained securitisation exposure), or                the standard CRM logic for credit exposures (location of the protection provider instead of location of the underlyings)?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1152/2014 - RTS on the identification of the geographical location of relevant credit exposures for institution-specific countercyclical capital buffer rate
  • ID: 2026_7830
  • Topic: Other issues
  • Date of submission:

Identical cell F_13.02.1 Collateral obtained during the period

Could you pls de-activate the 'identical cells' below in DPM 4.2.1? VariableVID = 5459395 ---> {F_13.02.1.a, r0020, c0010}=={F_13.02.1.c, r0080, c0040} ----> 120783==366904 VariableVID = 5460187 ---> {F_13.02.1.a, r0020, c0020}=={F_13.02.1.c, r0080, c0050} ----> 120791==366905    

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2026_7829
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 05/06/2026

Validation rule v7511

validation rule v7511m Z_03.01, c, default: 0, interval: true}: {r0400} = {r0410} + {r0420} + {r0430} + max({r0440}, {r0450}, does not seem to be complete as it does not consider Z0.3.01 r0460

  • 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_7828
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Templates Z07.01.2 - Timing of substitution for Lending

Please confirm the time buckets to be used for reporting col 0130 'Timing of Substitution' in template Z07.01.02 FUNC1 Lending

  • 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_7827
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Templates Z9.03 - Null values reportable in col 0020 Segment

Please confirm what should be populated in Template 9.03 col 0020 Segment as the taxonomy does not allow null values whereas Annex II instructions specify this should be reported for CCPs only.

  • 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_7826
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Templates Z09.02 - 'Country 0030 ' and 'Critical functions ID 0040' for Essential FMIs

Please confirm what should firms populate in Template 9.02 columns 'Country 0030 ' and 'Critical functions ID 0040' for non-critical FMIs as these columns cannot have null values.

  • 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_7825
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Template Z08.01: Reporting on intra-group services with identical LEI codes

Per EBA taxonomy, concatenation of col 0005, 0010, 0020, 0040, 0060 and 0130 in Template 8.01 should be unique (unique key).  This causes duplication error across rows reporting similar intra-entity services between different branches, i.e. identical providers/receiver codes and identical other fields required for unique key.Does the taxonomy need to be amended to allow such reporting?

  • 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_7822
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

incoherent formulae

The formula of control v90322_m seems not relevant.

  • 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_7821
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 13/05/2026