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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

Breakdown of currencies to be reported

What is the expected breakdown by currencies for the reporting of template J.01.00 and for the reporting of the other J templates [(J 02.00, J 03.00 and J 04.00), (J 05.00, J 06.00 and J 07.00), (J 08.00 and J 09.00) and (J 10.00 and J 11.00)] in the case that for J 01.00 the bank includes other currencies in addition to the minimum “material currencies” as defined in Article 1(3) of Delegated Regulation (EU) 2024/856 when reporting the aggregation of “all currencies”? Let us consider, for example, the case of a bank on which on a consolidated level three currencies (EUR, USD, GBP) are identified as “material currencies”, but the bank includes, on a voluntary basis, other currencies (e.g. MXN and BRL) for the calculation of the SOT, as it is considered in the bank’s internal management systems. Must the bank provide the breakdown by currencies for the J templates only for the “material currencies” (EUR, USD, GBP) or as well for the other “non-material currencies” (MXN and BRL)? 

  • 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
  • ID: 2024_7148
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:

Inclusion of Interim profits in CET1 ratio at half year

At the half year, where an institution has accrued for an interim cash dividend in line with its approved dividend policy and the policy also allows for the distribution of excess capital at the discretion of its Board, is the institution also required to deduct for a potential full year share buyback in its half year CET1 ratio where:  (i) its Board has not made any decision on an interim or full year share buyback and its distribution policy does not formally commit the institution to an interim / full year share buyback;  (ii) no share buyback application has been made to the ECB;  (iii) no explicit guidance on the quantum of a share buyback has been given to the market (at either the HY or FY), and therefore undistributed capital is fully available for use in H2 to cover unexpected risk or losses should they occur

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions
  • ID: 2024_7147
  • Topic: Own funds
  • Date of submission:

Internal hedges in the market risk thresholds computation

Should internal hedges be included in calculation of the size of institution's on- and off-balance-sheet business that is subject to market risk?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7146
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 31/07/2024

Application of large exposure rules towards companies designated as financial holding companies

Should exposures of a financial holding company (Company A) to a company that is not an institution or a financial institution and is not covered by prudential consolidation ("Company B") be included in the statement of large exposures on a prudential consolidated basis at the level of Company A, taking into account Company A is not an institution within the meaning of Art. 4, Para. 3 of Regulation 575/2013?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7144
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 31/07/2024

Retained collateralized issuances

Should assets used as collateral for retained issuances be treated as encumbered assets?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7140
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 31/07/2024

Exclusion of cash withdrawal services from PSD2

Is it a prerequisite for an ATM operator,to qualify for the exemption of article 3(o), to co-operate with a Payment Service Provider (authorised within the EEA or with a relative passport where necessasry) offering payment service number 2 of the Annex 1 of the PSD2?  

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7136
  • Topic: Other topics
  • Date of submission:

Maturity weighting of gross JTD amounts to calculate net JTD amounts

Are the maturity weighting of gross JTD amounts and three months floor of Art. 325x(3) applicable only to gross JTD amounts in cases where no offsetting is possible or are they applicable more generally to all gross JTD amounts?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7129
  • Topic: Market risk
  • Date of submission:

Collateral requirements for the ‚another credit protection‘ alternative in the form of cash on deposit held with a third-party credit institution

Does Article 26e (10) (b) of the Amended Securitisation Regulation allow cash collateral to be provided also in the form of a guarantee or letter of credit given by a qualifying third-party credit institution?

  • Legal act: Regulation (EU) No 2017/2402 (SecReg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7127
  • Topic: Simple Transparent and Standardised securitisation
  • Date of submission:

Sign Convention and aggregated rows in Template 2 of the ITS on IRRBB

Could the EBA please clarify the expected sign convention for columns 0040 to 0090 and 0110 to 0120, and the aggregation logic for rows 0540 to 0560 in template J 02.00?

  • 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
  • ID: 2024_7121
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 11/07/2024

Definition of "Communication Standards" under Article 30.3

a) Is ISO 20022 considered the communication standard referenced in Article 30(3) of the Regulatory Technical Standards (RTS), Commission Delegated Regulation (EU) 2018/389? b) How should NCAs ensure that ASPSPs comply with these standards, in accordance with Article 30.6 of the RTS?

  • 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: 2024_7118
  • Topic: Other topics
  • Date of submission:
  • Published as Rejected Q&A: 30/07/2024

Providing payment service via Internet banking (web-application)

Is providing payment service via Internet banking (web-application) payment initiation channel considered to be issuing of payment instruments? 

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/09 - Guidelines on authorisation and registration under PSD2
  • ID: 2024_7115
  • Topic: Authorisation and registration
  • Date of submission:

Unrated short term claim/exposure

As per CRR Article 120(para 3, subpara c), it states: "If there is a short-term assessment and such an assessment determines a less favourable risk weight than the use of the general preferential treatment for short-term exposures, as specified in paragraph 2, then the general preferential treatment for short-term exposures shall not be used and all unrated short-term claims shall be assigned the same risk weight as that applied by the specific short-term assessment." Question: What is meant by unrated short-term claims as per this paragraph? If there is a general issuer rating available, will the exposures with residual maturity of less than 3 months be classed as Unrated and not eligible for preferential risk weight treatment as per CRR Article 120 (2)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2024_7111
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/07/2024

Risk weight for Exposures in default

What risk weight should be applied to in default exposures, under the standardised approach for credit risk? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7110
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/07/2024

Revocation of ASPSP's Exemption from the Contingency Mechanism due to Prolonged Service Disruption

In a scenario where an incident lasting more than two consecutive weeks preventing Payment Service Users (PSUs) from initiating their payments through a dedicated interface, considering that the Account Servicing Payment Service Provider (ASPSP) has an exemption from the contingency mechanism under Regulation (EU) 2018/389, and the National Competent Authority (NCA) has been notified about the incident: Should the National Competent Authority (NCA) revoke the ASPSP's exemption from the contingency mechanism?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2018/07 - Guidelines on the exemption from the contingency mechanism under Regulation (EU) 2018/389
  • ID: 2024_7103
  • Topic: Other topics
  • Date of submission:

Template 3: Banking book - Indicators of potential climate change transition risk: Alignment metrics

Is it allowed to use another scenario than those prescribed by the IEA, as long as it is compatible with 1.5C trajectory and clearly documented in the narratives?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7102
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 28/06/2024

validation rules v16059_s and v16069_s for Template 3 are not aligned with above referenced article / paragraph in the ITS

We believe the validation rules are incorrect as they prescribe that the value should always be equal to or larger than zero, which is not always the case when applying the fixed formula for calculating the distance from the IEA Net Zero benchmark.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7100
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 05/07/2024

Loan commitments, financial guarantees and other commitments received in F 9.2

Could you please more precisely clarify what should be presented as “Loan commitments, financial guarantees and other commitments received” in F 9.2?

  • 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
  • ID: 2024_7099
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:

Misalignment between scope of reportable exposures against public authorities in template 7 ( CRR) and template 1 ( EU Taxonomy - acc to 2021/2178)

Should rows 280, 290 and 300 from Template 7 under ESG Disclosure only be limited to "Loans and advances" or should the scope of the rows be extended by including also debt security exposures (or other categories of exposures) in order to align with  Annex V from European Commission published on 27.6.2023 , updating Section 1.2.1.4 from 2021/2178 ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7097
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 28/06/2024

Maximum amount of the collateral or guarantee that can be considered in F 13.01 and F 18.00

Could you please more precisely clarify what should be used for “Maximum amount of the collateral or guarantee that can be considered”? Primarily use Market value of collateral as it is prescribed in ESRB Recommendation? or  Each Institute can have individual approach, where Internal collateral value (Market value of the assets reduced by a certain percentage => the “haircut”) also can be primarily used?

  • 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
  • ID: 2024_7095
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 14/06/2024

Clarification needed in dedicated Interfaces supervision

We seek clarification and insights into how competent authorities shall fulfill their responsibilities in line with Recital 23 and Article 32.2 of the Commission Delegated Regulation (EU) 2018/389, specifically regarding the supervision of payment initiation service's dedicated interfaces to ensure effective oversight and monitoring.

  • 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: 2024_7093
  • Topic: Other topics
  • Date of submission:
  • Published as Rejected Q&A: 30/07/2024