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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

C14.01 - EBA VR v7338_m

The EBA Validation Rule v7338_m applicable to the C14.01 template states that the exposure value deducted from own funds (c0420) should be equal or lower than the original exposure pre-conversion factors, split by tranches (c310, c320, c330, c340, c350, c360). Should this control be applicable?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7963
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026

C14.00 - EBA VR v7349_m

The EBA Validation Rule v7349_m applicable to the C14.00 template states that the total exposure amount of the underlying assets at the reporting date (c0140) should be equal or lower than the sum of the on-balance sheet exposure amounts of the secutitisation's tranches (c0230, c0240, c0250).  Should this controls be applicable?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7962
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026

Template C 14.00 - Validation rule v7349_m_0 and the treatment of overcollateralisation reported in column c0254

Validation rule v7349_m_0 requires that: {C 14.00, c0140} ≤ {C 14.00, c0230} +{C 14.00, c0240} +{C 14.00, c0250} However, the validation rule does not take into account amounts reported in column c0254 (Overcollateralization and funded reserve accounts). At the same time, the reporting framework distinguishes overcollateralization and funded reserve accounts from the amounts reported in the senior, mezzanine and junior tranche columns. Furthermore, EBA Q&A 2023_6694 clarified that where an overcollateralization position meets the definition of a tranche it should be reported in the relevant tranche columns, whereas overcollateralization that does not meet the definition of a tranche should be reported in column c0254. In a securitization transaction where a portion of the credit enhancement is appropriately reported in column c0254 and does not constitute a tranche, the amount reported in column c0140 may exceed the sum of columns c0230, c0240 and c0250 solely because the amount reported in c0254 is excluded from validation rule v7349_m_0 which would result in the validation rule v7349_m_0 failing. Could the EBA clarify the intended application of validation rule v7349_m_0 in such cases? In particular: Should amounts reported in column c0254 be considered for the purposes of validation rule v7349_m_0, despite not being explicitly included in the formula? Alternatively, does the validation rule reflect the assumption that any overcollateralization relevant for this comparison should be reported within the tranche columns (c0230-c0250)? Where overcollateralization reported in c0254 does not meet the definition of a tranche, what is the expected reporting treatment considering in this instance that compliance with validation rule v7349_m_0 cannot be achieved?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2026_7958
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026

The control formula v11889_m lacks sufficient evidential value.

Only the Total sheet  ([eba_qAE:qx2023]) must be empty for column 0070 (LGD).  Should control over another sheet (other than [eba_qAE:qx2023]) really exist ? Should it not be deleted ?

  • 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_7952
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

The control formula v11888_m lacks sufficient evidential value.

Only the Total sheet  ([eba_qAE:qx2023]) must be empty for column 0050 (PD).  Should control over another sheet (other than [eba_qAE:qx2023]) really exist ? Should it not be deleted ?

  • 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_7951
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

The control formula v10666_m lacks sufficient evidential value.

The control rule in place is incompatible with the EBA Filing Rules - section 2.18 on decimal precision requirements. Could these rules be amended?

  • 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_7950
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

The control formula v10664_m lacks sufficient evidential value.

The control rule in place is incompatible with the EBA Filing Rules - section 2.18 on decimal precision requirements. Could these rules be amended?

  • 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_7949
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026

Validation Rule v22950_m – warning generated for exposure class [eba_qEC:qx2038] in C 07.00a

Validation rule v22950_m requires that cells in C 07.00a, row 0062 are blank for exposure class [eba_qEC:qx2038] – “Exposures secured by mortgages on immovable property and ADC”. However, the instructions for row 0062 state: “of which: IPRE exposures where the derogation set out in Article 125(2) of Regulation (EU) No 575/2013, second subparagraph is applied. Only reported in sub-exposure class ‘Secured by mortgages on residential immovable property – IPRE’.” According to the DPM hierarchy, qx2038 is the parent exposure class of – ‘Secured by mortgages on residential immovable property – IPRE’. As amounts reported are reflected in the corresponding parent exposure class, the inclusion of qx2038 in validation rule v22950_m generates a warning despite the reporting being consistent with the instructions.  Rule Reference: isnull ({tC_07.00.a, r0062, (c0010, c0030, c0040, c0150, c0160, c0165, c0170, c0175, c0180, c0190, c0195, c0200, c0215, c0220), default: null, interval: false} [ where qEBB in {[eba_qEC:qx16], [eba_qEC:qx23], [eba_qEC:qx22], [eba_qEC:qx21], [eba_qEC:qx20], [eba_qEC:qx19], [eba_qEC:qx2043], [eba_qEC:qx2036], [eba_qEC:qx2060], [eba_qEC:qx2037], [eba_qEC:qx2061], [eba_qEC:qx2063], [eba_qEC:qx2049], [eba_qEC:qx12], [eba_qEC:qx2050], [eba_qEC:qx13], [eba_qEC:qx18], [eba_qEC:qx14], [eba_qEC:qx1], [eba_qEC:qx25], [eba_qEC:qx26], [eba_qEC:qx2038], [eba_qEC:qx2039], [eba_qEC:qx2040], [eba_qEC:qx2041]}]) 

  • 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_7946
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

Maturity of a trading book position

For the purpose of calculating the Expected Shortfall under Article 325bd(4), can “the maturity of the trading book position” (parameter ‘Mat’) be interpreted to mean the time for which the exposure remains sensitive to the risks of the position currently held? For example: for a physical delivery derivative, it would be the maturity of the underlying. For others, it would depend on the capacity of replacing the position, which should typically be met for liquid listed derivatives.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7944
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2026

Validation rule EBA_v22949

Validation rule v22949 should be deactivated as it is not in line with reporting instructions.

  • 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_7942
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026

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

Clarification on the application of NACE classification versions (Rev. 2 vs Rev. 2.1) across Pillar 3 disclosures and supervisory reporting

Under the recent Pillar 3 Update on ESG risk, equity and shadow banking exposure release by EBA, EBA has introduced the use of the updated NACE Rev. 2.1 classification in certain templates. In particular: Template CQ5 has been amended to reflect economic activities based on NACE Rev. 2.1, as set out in Commission Delegated Regulation (EU) 2023/1372. Other ESG-related Pillar 3 templates (e.g. CR FR1 and CR FR2) have also been updated to incorporate the revised NACE classification and enhanced sector definitions. At the same time, based on the current EBA ITS on supervisory reporting, the FINREP template F 06.01 (Breakdown of loans and advances by economic activity) appears to continue to rely on NACE Rev. 2 (Regulation (EC) No 1893/2006). Given that: Pillar 3 template CQ5 is typically mapped or reconciled to FINREP template F 06.01, and Different NACE versions are now being applied across these frameworks, In this context, could EBA please clarify whether institutions are expected to apply different NACE versions (Rev. 2.1 for Pillar 3 vs Rev. 2 for FINREP/COREP) in parallel?  Is the EBA planning to update FINREP and COREP to incorporate NACE Rev. 2.1 in the near future, in order to ensure alignment with Pillar 3 disclosures?

  • 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: 2026_7935
  • Topic: Transparency and Pillar 3
  • Date of submission:

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

Annex II: Instructions II. 21 - Relevant Services - mapping to operational assets (SERV 2) - column 0040 classification"Type of Asset" for Software

How should business applications that consist of software be classified in column C0040 "Type of asset" of template Z08.02? The drop-down list for C0040 does not explicitly refer to business applications or software assets. Please clarify which asset type should be selected when reporting business applications to ensure a consistent interpretation and application of the reporting requirements.

  • 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_7930
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2026

Completion of the Z08.02 Template

In Z_08.02, are we expected to map operational assets to external services or only to intra-entity services?  If we are expected to map operational assets to external services, for external services which relate to support we receive on IT systems, should columns 0030, 0080, 0040 and 0050 be populated with data related to the respective IT system or should they be left blank? Additionally, if we report a service related to physical transportation of cash, should columns 0030, 0080, 0040 and 0050 be left blank considering that we don't need any asset to receive the service from the external provider?    

  • 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_7927
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 18/09/2026

Template Z08.02: Reporting of applications owned and operated by affiliated service providers

Where a reporting entity receives services from an affiliated entity and relies on applications that are owned, managed and operated by that affiliated service provider, should those applications be reported in template Z08.02 by the receiving entity?Alternatively, should template Z08.02 be limited to operational assets that are owned, managed or directly controlled by the reporting entity, with dependencies on affiliate-owned applications being reflected through the relevant service provider and outsourcing/inter-affiliate reporting templates?

  • 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_7926
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 18/09/2026

Instructions to follow regarding new EBA Resolution Reporting - Template Z 07

Could the EBA please confirm whether column “0030” (and, for template Z 07.01.4, also columns “0040” and “0050”) should be populated with amounts referring to the entire customer base, irrespective of residence, or with amounts referring only to customers resident in the home country?

  • 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_7924
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026

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