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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

Scope of fair-value instruments included in delta MV under the standardised methodology

How should an institution that applies the standardised methodology calculate the market value changes reported in template J 01.00, rows 0150-0170, for instruments held at fair value that mature or reprice within the one-year net interest income horizon? Article 21 of Commission Implementing Regulation (EU) 2024/3117 requires institutions to submit template J 01.00 in Section 12 of Annex I. The instructions for rows 0150-0170 of that template require institutions to report delta MV using, where applicable, Article 22 of Commission Delegated Regulation (EU) 2024/857. The same instructions require that the total size and composition of the amount whose value is sensitive to delta MV be maintained by replacing maturing instruments with new instruments that have comparable features, including currency and nominal amount. Article 22 is limited to market value changes of instruments held at fair value maturing beyond the net interest income time horizon. Article 22(2), point (b), requires notional cash flows that reprice within that horizon to be set to zero. The net interest income time horizon is at least one year. Two interpretations have emerged: Article 22 reading. For institutions applying the standardised methodology, rows 0150-0170 contain only the Article 22 measure: fair-value instruments maturing beyond the net interest income horizon, with cash flows repricing inside that horizon excluded. Instruments maturing within the one-year horizon are not replaced for the purpose of delta MV. Their interest-rate effect inside the horizon is reported in delta NII. Constant balance sheet reading. The replacement sentence applies to the delta MV population itself. Instruments held at fair value that mature within the one-year horizon are replaced by new instruments of comparable currency and nominal amount, and the market value change of those replacement instruments is included in rows 0160 and 0170, in addition to the Article 22 measure for instruments maturing beyond the horizon. Should rows 0150-0170, where the standardised methodology applies, follow Article 22 and exclude instruments maturing within the net interest income horizon, or should those instruments be replaced and included in delta MV?

  • 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_8020
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 30/10/2026

Inconsistencies in DPM 4.4

Overlapping numbering of rows/columns detected in report sections of the (Draft) taxonomy on what, as per the ITS/Annotated Tables, are one report. Will this be aligned?

  • 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_8018
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026

SME supporting factor application on PSE exposures secured by immovable properties

Does Article 501 CRR allow application of the SME supporting factor in case (1) solely because of that reassignment to Article 112, point (i), even though the same obligor’s unsecured exposure in case (2) is not eligible?

  • 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_8011
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026

Disclosure of liquidity requirements - NSFR - LIQ2. Number of quarters to be disclosed in the Disclosure Period

In Q&A 2025_7533, EBA has confirmed that "for half-year disclosures, two data templates representing the first (Q1) and the second quarter (Q2) of the current disclosure year" are required to be disclosed in disclosure template EU_LIQ2. However, according to EBA DPM (20260106 Annotated Table Layout  PILLAR3 4.2 CODISPILLAR3 4.2), there is a dependency between reporting periods reported in EU_KM1 (K_61) and those reported in EU_LIQ2 (K_74). Specifically, EU_KM1 (K_61) requires more than two reporting periods. As a result, it is not possible to report only two periods in EU_LIQ2, as suggested in Q&A 2025_7533, without violating the predefined DPM rules.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_8006
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2026

Value accepted for ID Code of the Type of the instrument is no longer in line with regulator's requirement

Since last update of Invoke, the value accpeted for colomn FC0101 of the template FC.01 is the following closed list of choices: Banking sector; Insurance sector, Investments services sector and Other undertaking of the groupe. However, according to regulation (EU) 2022/2454, this column is related to ID code type of the instrument and the following is instructed : Type of ID code used for the ‘ID code of the instrument’ item. One of the options in the following closed list of codes shall be used: 1 -ISO 6166 for ISIN code 2 -CUSIP (the Committee on Uniform Securities Identification Procedures number allocated by the CUSIP Service Bureau for United States and Canadian companies) 3 -SEDOL (Stock Exchange Daily Official List for the London Stock Exchange) 4 -WKN (Wertpapier-Kennnummer, the alphanumeric German identification number) 5 -Bloomberg Ticker (Bloomberg letters code that identifies a company’s securities) 6 -BBGID (the Bloomberg Global ID) 7 -Reuters RIC (Reuters instrument code) 8 -FIGI (Financial Instrument Global Identifier) 9 -other code provided by members of the Association of National Numbering Agencies 99 –A code allocated by the undertaking.

  • Legal act: Directive 2002/87/EC (FiCOD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2454 – ITS on the reporting of intra-group transactions and risk concentration for financial conglomerates
  • ID: 2026_8003
  • Topic: Financial conglomerates
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2026

RW applicable to defaulted IPRE exposures

Given that Article 127(2) states that the secured part of a defaulted exposure considers collateral and guarantees eligible for credit risk mitigation under Chapter 4, and that real estate collateral is not regarded as eligible mitigation under the Standardised Approach (SA), while Article 127(3) applies the 100% risk weight only to non-IPRE exposures, should the risk weight (RW) for all defaulted IPRE exposures be determined according to Article 127(1), i.e., based on the level of specific credit risk adjustments?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7997
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026

Application of the risk weight of 100% to defaulted non-IPRE exposures

For non-IPRE defaulted exposures, is the 100% risk weight (RW) applicable only up to 55% of the property market value (LTV), or up to the full amount of the lien or mortgage value (if lower than the mortgage value)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7996
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026

Risk weight (RW) applicable to defaulted ADC and IPRE-Other exposures

For defaulted ADC and IPRE-Other exposures, should the applicable risk weight (RW) remain 150%, consistent with the RW applied before they become defaulted, or should banks apply the risk weighting rules set out in Article 127(1) of the CRR3?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7995
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026

Spot instrument on unallocated Gold are subject to counterparty risk

Are spot instrument on unallocated Gold subject to counterparty risk?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7994
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 22/09/2026

Instrument on unallocated Gold according to alternative standardised approach for market risk

Should the gold sensitivities of instruments related to unallocated gold, as calculated under the alternative standardized approach for market risk, be included in commodity risk or foreign exchange risk?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7993
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 22/09/2026

Credit index tranche as securitization?

Should credit index tranches be treated as securitizations for prudential purposes, or as credit derivatives? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7990
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2026

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

Applicability of the prior permission requirement under Article 26(3) CRR to investment firms subject to Regulation (EU) 2019/2033 (IFR)

Article 26(3) CRR provides that institutions shall classify issuances of capital instruments as Common Equity Tier 1 (CET1) instruments only with the prior permission of the competent authorities. Article 2(5) CRR requires competent authorities to treat as "institutions", for the purposes of the CRR, only those investment firms to which Article 1(2) or 1(5) IFR applies (Class 1 firms). Investment firms subject to the IFR (Class 2 and Class 3 firms) apply the definition of CET1 capital by virtue of Article 9(1)(i) IFR, which refers to Part Two, Title I, Chapter 2 of the CRR. Do Class 2 and Class 3 investment firms require prior permission from their competent authority under Article 26(3) CRR in order to classify issuances of capital instruments as CET1 instruments?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7987
  • Topic: Capital requirements
  • Date of submission:
  • Published as Rejected Q&A: 22/09/2026

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

Clarification on the use of external credit assessments when determining HQLA eligibility of assets representing a claim on a third-country central government

We seek clarification on the use of external credit assessments when determining HQLA eligibility under the provision of Article 10(c)(ii).  Specifically, where an asset representing a claim on a third-country central government has a residual maturity of less than one year: Can a short-term credit assessment from a nominated ECAI corresponding to Credit Quality Step 1 (CQS 1) be used for the purpose of determining eligibility as a Level 1 asset? Where both long-term and short-term credit assessments are available, which assessment should be used for the purposes of the HQLA eligibility assessment? More generally, we would be grateful for any guidance on the circumstances in which short-term external credit assessments may be used when assessing eligibility of assets for inclusion in the HQLA buffer under the LCR framework.

  • 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_7975
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 22/09/2026

Z07.01.3 securities settlement services : content of number of clients

In the annex for IT solution of RESOL reporting Number of clients the following guidelines are given : Number of (resident and non-resident) clients to which the service is provided

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7974
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2026

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

F40.1 'Accumulated Equity interest' and 'Voting rights'

Template F40.1: For the purpose of reporting the institution’s “Accumulated equity interest [%]” and respectively the “Voting rights [%]” in an indirect subsidiary, is it correct to consider the indirect interest or the direct interest?  In other words, when Annex V refers to the percentage of ownership instruments and voting rights “held by the institution”, should this be assessed at the level of the reporting institution (ultimate parent undertaking) or at the level of the entity directly holding the interest in the subsidiary?

  • 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_7967
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026