Search for Q&As

Enquirers can use various factors to search for a Q&A:

  • These include searching by the Q&A ID; legal reference, date submitted, technical standard / guideline, or by keyword if known.
  • Searches can be extended to more than one legal act, topic, technical standard or guidelines by making multiple selections (i.e. pressing 'Ctrl' on your keyboard, and selecting the relevant ones from the drop-down lists by left mouse-click).

Disclaimer:

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.

Final Q&As Q&As under review Rejected Q&As Archived Q&As All Q&As

List of Q&A's

Application of Article 254(2) to derivative exposures

Is new Article 254(2) CRR applicable to derivatives positions to hedge market risk?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4465
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as final Q&A: 15/11/2019

Validation rule v1088_m

Validation rule v1088_m verifies that the amount entered in F01.01 row 280, column 010 (Property, Plant and Equipment in the Balance Sheet Statement) should be equal or larger than the amount entered in F13.02 row 020, column 010 (Property, Plant and Equipment obtained by taking possession during the period). This validation rule implies that collateral obtained in the form (nature) of Property, Plant and Equipment is classified in the Balance Sheet Statement as Property, Plant and Equipment. We believe in most cases the collateral obtained by taking possession will be classified as either held for sale (based on IFRS 5.6 and meeting the requirements from IFRS 5.7) or as “other assets” (based on meeting the conditions of IFRS 5.6, but not IFRS 5.7 (plan for immediate sale in present condition and sale being highly probable)) and thereby will be reported in either F01.01 row 370, column 010 or F01.01 row 360, column 010. We therefore question whether the current validation rule is appropriate.

  • 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: 2019_4464
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Clarification of negative RWA--, Annex III, Benchmarking exercise

What should we do if the value of RWA-- gets negative? Should we do nothing or should the value change to example 0?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2019_4459
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Offset of Additional Value Adjustments (AVA) against day one profits deferral

Under Article 8(3), is day one profit deferral eligible to offset the AVAs under Articles 9, to 17 of Regulation (EU) No. 2016 / 101?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/101 - RTS for prudent valuation under Article 105(14) CRR
  • ID: 2019_4458
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 29/11/2019

Unique row identifier for template Z 08.00 - Critical services (SERV)

According to Annex II to ITS on Reporting for Resolution Plans, the combination of values regarding Service type, Service recipient, Service provider, Critical function and Country shall define a unique row identifier.Given that the combination of values defined as row identifier in template Z 08.00 of Annex II to the ITS on Reporting for Resolution Plans may actually be common to different contracts having different contractual provisions, how, if at all, should institutions report these contracts? (i.e. do institutions have to report one row for each contract, identified by field 0005 Identifier, which would be part of the single row identifier?)

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on the provision of information for the purpose of resolution plans
  • ID: 2019_4457
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Allocations to the funds for general banking risk

Can banks allocate items to their funds for general banking risk without waiting for the annual accounts? If yes, is Art. 26 (2) CRR applicable for allocations during the financial year?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4453
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Potential inconsistency on the application of Strong Customer Authentication exemptions to AISPs

Shall Account Servicing Payment Service Providers (ASPSPs) always grant Account Information Service Provider (AISPs) to be exempted from Strong Customer Authentication (SCA) according to rules defined in Article 10 of the RTS on strong customer authentication and secure communication (Delegated Regulation (EU) 2018/389), or is the final decision to apply such exemption always up to the ASPSP?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2019_4450
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

IRRBB Application of the sudden parallel

How should banks apply the sudden parallel +-200 basis points shift of the yield curve in their forecast yield curve?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2015/08 - Guidelines on the management of interest rate risk arising from non-trading activities
  • ID: 2019_4448
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 15/11/2019

To which exposure class the fair value changes of the hedged items in portfolio hedge of interest rate risk should be assigned

To which exposure class the 'fair value changes of the hedged items in portfolio hedge of interest rate risk' (recorded in the IFRS consolidated financial statements in accordance with (IAS 39.89A(a); IFRS 9.6.5.8) have to be assigned. The recorded exposure relates to a bottom layer macro fair value hedge of mortgage loans. Due to the application of the bottom layer macro fair value hedge approach there is no individual allocation of the exposure value of the hedged item to the individual mortgage loans. Should this exposure be treated as an 'exposure secured by mortgages on immovable property' or as 'other items', and subsequently, which risk weight should be applied to this exposure.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4441
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Revocation / Invalidation of SCA proof before execution date

In order for a payment instruction to be regarded as 'authorised', is the Account Servicing Payment Service Provider (ASPSP) obliged to verify the strong customer authentication (SCA) proof immediately prior to the execution of each future dated payment instruction? If the ASPSP fails to re-verify the SCA proof, can the ASPSP hold the payer liable in the event of fraud?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4440
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 17/12/2021

Fraud rate calculation for TRA exemption – country dimension

Could – or should – the fraud rate for the TRA exemption be calculated per member state where a PSP provides payment services (one legal entity with branches in different countries), or should the fraud rate be aggregated as one for the whole legal entity?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4439
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 12/04/2019

SA or IRB treatment of CCPs for AIRB banks

Does article 306(1)(b) of the CRR imply (or not) that trade exposure and default fund contributions to non-qualifying CCPs should be considered as exposures designated to the SA even in case an IRB authorization exists?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4437
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Prudent valuation - new template C.32.01

At the analysis of the new template C.32.01 which must be filled starting from reporting date 31.12.2018 we found some constellations which we cannot allocate so easily in the new form. Here we would ask you for guidance. 1. Eurex-Netting Here derivatives of different hedging relation and valuation categories are netted and the netting result is finally shown in only one finrep position which is derivatives – hedge accounting (in the template rows 1.1.9 or 1.2.4). Here are also some derivatives included for which the hedging relation should be shown in column 030 exactly matching. The reason is that the other deal of the hedging relation which is not part of the netting agreement is also shown here. At the rows 1.1.9 or 1.2.4 the column exactly matching is, however, shown greyed out. If we – for instance – evade to column 040 other, then column exactly matching does no longer show the same total on the asset side and the liabilities side what – we suppose – would contradict to the expectations of EBA. How can we show this constellation properly in the template? 2. Portfolio Fair Value Hedge Accounting (rows 1.1.10 and 1.2.5 in the template) We regard the bookings in this balance sheet positions also as a part of hedge accounting and thus cannot understand why in these rows 1.1.10 and 1.2.5 column 040 hedge accounting is shown greyed out. Where can we show in the template the deduction items which we calculate for prudent valuation at portfolio fair value hedge accounting? 3. Change of algebraic sign at some trades There are cases where the total book value is lower than the hedge adjustment included in the book value. This means that after elimination of the hedge adjustment in column 030 or 040 the algebraic sign of the book value changes. In the result column 080 the problem is solved by showing the absolute value for the calculation basis for the prudent valuation of every deal. So undesirable netting effects inside this column are avoided. At the deduction rows 030 – 060 it is not so easily possible to show a transparent calculation. Example: Deal 1 Book value 80 Hedge Adjustment 100 Result 20 (absolute value) Deal 2 Book value 100 Hedge Adjustment 90 Result 10 (absolute value) Then the cells in template show the following figures: Book value 180 Hedge adjustment 190 Result 30 (absolute value) This is correctly calculated, but not transparent and the validation rules are not complied with.

  • 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: 2018_4436
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2022

Dynamic Linking for batch payments

With regards to dynamic linking for a batch of remote electronic payments, should the authentication code be linked to each and every IBAN of all the beneficiaries in a batch file?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4435
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 20/12/2019

[eba_v1042_m] f16.01

Why the total of the table F16.01.b doesn't follow the rule [eba_v1042_m]? Is this related to negative interest rates?

  • 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: 2018_4434
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 08/05/2020

Operational Risk business line mapping

When an entity carries out an activity for retail customers in a supportive manner to lending and taking deposits from customers in such a way that the entity has neither a separate organisational unit nor a specific internal P/L account for this activity, should it be allocated to the retail banking business line? On the other hand, if the said activity is carried out by the entity in a separate organisational unit with its internal management accounting statements (not necessarily a different legal entity), should its relevant indicator (calculated from the management P/L account) be mapped into the business line established by Article 317 CRR (as an example, in the case of placement of financial products, to retail brokerage)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4433
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Passporting and eIDAS certificates

Do account servicing payment service providers (ASPSPs) have to check that third party providers (TPPs) are authorised to operate in their Member State via freedom to deliver services passporting? If so, how shall this be done?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4432
  • Topic: Passporting
  • Date of submission:
  • Published as final Q&A: 26/04/2019

Treatment of joint credit obligations

Do the requirements established in the Guidelines on the application of the definition of default under Article 178 of Regulation (EU) No 575/2013 regarding joint credit obligations, and in particular the requirements 95, 96, 97, 98, 99, 103, 104 and 105, relate or affect exclusively to retail exposures? In that case, could the treatment of joint credit obligations in which the obligors are classified as Non – Retail differ from the treatment of joint credit obligations in which the obligors are classified as Retail? In addition, and, as per this purpose, what should be the treatment of joint credit obligations shared by retail and non-retail obligors?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/07 - Guidelines on the application of the definition of default under Article 178 CRR
  • ID: 2018_4431
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 07/08/2020

Application of the Low Value Transaction Limits

Should the limits according the Article 16 RTS be applied to the account itself (account holder and authorized persons together) or should they be applied to the account holder (owner) and each authorized person (i.e. proxy of account holder) separately? Subsequently should the limits be applied to all remote payment transactions together or should e.g. card transactions and credit transfers be counted separately. Also should the limit be applied to all cards belonging to one person together or should the limit be applied to each card separately?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4429
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 26/04/2019

EBA ITS package for 2019 benchmarking exercise (Annex V, section 2, FX instruments)

What is the correct interpretation of instrument No.40?

  • 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: 2018_4428
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 26/07/2019