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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.

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

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

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

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

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

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

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

Pillar 3 Transparency - Risk weight missing in Template CCR3

Values with risk weight 30% are not allocated (according to the EBA Mapping Tool) to template CCR3, although these values appear in Row 185 of template COROFC C07.00. Is it intended to exclude values with 30% risk weight from template CCR3 (if yes, please provide the reasons for that) or is this a bug in die EBA mapping tool?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Definition of "official export credit agency" for the calculation of deduction for non-performing exposures

Article 47c(4a) of the CRR exempts the part of a non‑performing exposure guaranteed or insured by an “official export credit agency” (ECA) from the deduction requirements laid down in Article 47c. However, the CRR does not define the term “official export credit agency”. In this context, what are the criteria for qualifying as an “official export credit agency” and how can it be determined whether an export credit agency and the guarantee or insurance provided meets the criteria for applying the derogation as provided in CRR Article 47c(4a)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Z 09.02 (FMI2) FMI services reporting criteria

Could the EBA confirm the correct reporting criteria for columns 0040 (Critical Function ID) and 0060 (Core Business Line ID) in template Z 09.02 when an FMI is classified as either essential or critical, but not both, and the procedure to follow when an FMI maps to multiple functions or business lines?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Concerns on reporting on all relationships between investor and investee in Z01.02 of RESOL1 in alignment with the indication of key value as marked in the DPM 4.2 module

How to report correctly on the relationship of the investor (Z01.02, column 0020 “Code”) and the investee (Z01.02, column 0050 “Code”) when the investor invests in multiple investees? Could you please adjust the technical requirements stated in the Annotated Table Layout in the DPM 4.2 module (20260106 Annotated Table Layout RES 4.2 RESOL1RES 4.2.xls) and apply the setting of ‘Key value’ to both column 0020 as well as to column 0050?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Unique values in Z.01.02 in column 0020

How are institutions expected to report repeated values in column 0020 of template Z 01.02?

  • 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

Application of Article 199(6)(d) for low default portfolios

In cases where institutions do not have a sufficient internal track record of default and liquidation events due to the low-default nature of certain portfolios, is there an alternative approach, such as the use of relevant external data, market evidence, or a combination of internal and external information, that could be considered acceptable to demonstrate compliance with Article 199(6)(d) for eligible physical collateral?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Z01.02 - Ownership structure: Investor code and type of code for multiple investments

According to the Annotated Table Layout of DPM 4.2, c0020 - Code (Investor Code), is specified as a unique ID in the template. According to the instructions for filling out the template, the specification must maintain referential integrity with Z01.01, provided that the investor is a group company.Since there can exist multiple investments per investor, it is not possible to comply with these requirements completely. How shall c0020 and c0030 (Type of code) be reported in such cases ? 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Z0200 - templates that should be reported on an individual basis

Regarding the templates that should be reported on an individual basis, for itself and for each relevant legal entity in the group (for example, the information specified in template Z 02.00 that should be reported according to the art. 4 letter (b) of CIR 2025/2303), the question is: Can the bank include also in its individual resolution report templates Z 02.00 for each relevant legal entity in the group or the relevant legal entities have to report the templates on an individual basis for themselves? If the bank can include also in its individual resolution report templates Z 02.00 for each relevant legal entity in the group, how can this be done from a technical point of view?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Z 07.01.1 to Z 07.01.5 consolidated reporting

Regarding the templates Z 07.01.1 to Z 07.01.5 that should be reported for each Member State in which the group is active (as specified in Annex 1 to the regulation mentioned above), the question is: Could you please confirm if the bank can include separate templates for each country in a single individual resolution report?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Completion of Z08.x Templates

Does the “Unique service title” in Column 0020 of Z08.01 need to be unique to every contract i.e, if we have 150 different contracts should we have 150 different “Unique service titles” or can we have multiple contracts sharing the same service title? If we can have multiple contracts sharing the same “Unique service title”, should the “Service identifier” in column 0005 of Z08.01 be the same for each contract having a particular “Unique service title”? In Z08.01 can we assign multiple “Unique service titles” (Column 0020) and multiple “Service types” (Column 0010) to the same contract? In Z08.02 should the “Asset identifier” in Column 0030 be unique to each asset or to each contract? By way of example, if we have two contracts for leasing of two different premises, should we assign them the same asset identifier or a different one? In Z08.02 Column 0120, should contracts which require us to pay for the service in advance be considered to have an “Alternative mitigating action”? In Z08.03 Column 0030, if we have the same role name (e.g. “analyst”) across multiple departments should that role have the same “Role ID” across all departments or should we assign one ID per department? In Z08.03 Column 0060, should the “Criticality” value be the same as that in Column 0120 of Z08.01? If contracts can share a “Unique service title” (column 0020 of Z08.01) and the “Service identifier” (column 0005 of Z08.01) should be the same for the same service title, does that mean that each row in Z08.03 can represent multiple contracts? In Z08.03 can we assign multiple roles to the same contract? If contracts can share a “Unique service title” (column 0020 of Z08.01) and the “Service identifier” (column 0005 of Z08.01) should be the same for the same service title, does that mean that each row in Z08.04 can represent multiple contracts? In Z08.04, can we assign multiple critical functions (Columns 0030 and 0040) to the same contract? If contracts can share a “Unique service title” (column 0020 of Z08.01) and the “Service identifier” (column 0005 of Z08.01) should be the same for the same service title, does that mean that each row in Z08.05 can represent multiple contracts? In Z08.05 can we assign multiple core business lines (Column 0030) to the same contract?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Inconsistencies between ITS on resolution planning reporting versus Annotated Table Layout DPM 4.2, RESOL1 and RESOL2

Could you please align the technical requirements stated in the Annotated Table Layout in the DPM 4.2 module (20260106 Annotated Table Layout RES 4.2 RESOL1RES 4.2.xls) with the requirements as stated in the ITS (Annex II: Instructions) on Z11.00, column 0060 Governing Law (as well in Z12.00 column 0070, Z13.00 column 005, Z14.00 column 0070, Z15.00 column 0100, Z08.01 column 0140, Z08.02 column 0090, Z09.01 column 0130)? 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Inconsistencies between ITS on resolution planning reporting versus Annotated Table Layout DPM 4.2, RESOL1 and RESOL2

Could you please align the technical requirements stated in the Annotated Table Layout in the DPM 4.2 module (20260106 Annotated Table Layout RES 4.2 RESOL1RES 4.2.xls) with the requirements as stated in the ITS (Annex II: Instructions) on Z11.00, column 0100 Currency (as well in Z12.00 column 0090, Z13.00 column 0060, Z14.00 column 0120, Z17.00 column 0100, Z09.01 columns 0150-0200)? 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Inconsistencies between ITS on resolution planning reporting versus Annotated Table Layout DPM 4.2, RESOL1 and RESOL2

Could you please align the technical requirements stated in the Annotated Table Layout in the DPM 4.2 module (20260106 Annotated Table Layout RES 4.2 RESOL1RES 4.2.xls) with the requirements as stated in the ITS (Annex II: Instructions) on Z05.01/Z05.02, column 0040 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