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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

FINREP – Loan commitments, financial guarantees and other commitments given

In the context of FINREP template F 09.01, could the EBA clarify whether the scope of columns 0100 and 0110 is intended to include exposures (commitments and certain contractual arrangements that are not commitments as referred to in CRR Article 5/110a/111(4)) that fall under CRR3 Annex I but are not recognised or disclosed under IFRS 9, IFRS 7 or IAS 37?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2025_7592
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Investment of funds received in exchange of e-money tokens

Do banks (credit institution) need to maintain segregated account to safeguard the proceeds from e-money token issuance?

  • Legal act: Regulation (EU) No 2023/1114 (MiCAR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7591
  • Topic: Other MiCAR topics
  • Date of submission:
  • Published as Rejected Q&A: 11/11/2025

Annual reporting for GSIIDISPILLAR3 to the Competent Authorities under DPM 4.2

Should the Reporting Framework 4.2 related taxonomy be considered for the 2025 end-of-year reporting for GSIIDISPILLAR3 ? Pursuant to the last corrections included in DPM 4.2 for the GSIIDISPILLAR3 templates, respectively the removal of the GSIB column in the Annotated Table Layout for GSIIDISPILLAR3 4.2 (all the greyed-out cells under the column 0009 indicating non-applicability and for which the datapoints were doubled in DPM 4.1), we kindly request the confirmation that the DPM 4.2 can be used for the 2025 end-of-year reporting.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1030/2014 - ITS on disclosure of values used to identify global systemically important institutions (as amended)
  • ID: 2025_7590
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 12/01/2026

Access to national credit databases for all EU creditors for both cross-border and domestic mortgage loan transactions

Considering that Article 19 of Directive (EU) 2023/2225, repealing Directive 2008/48/EC (the ‘Consumer Credit Directive 2’), grants creditors from a Member State other than the one where a credit database is located access to that database only in relation to cross-border credit transactions, does the reference to the framework of Directive 2008/48/EC in Recital 20 of Directive 2014/17/EU (the ‘Mortgage Credit Directive’) imply that Article 21 MCD likewise provides creditors with access to databases solely for cross-border credit transactions?

  • Legal act: Directive 2014/17/EU (MCD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7588
  • Topic: Creditworthiness assessments
  • Date of submission:

Deduction of pledged own shares from Common Equity Tier 1 items

Institutions, in the context of private banking and or corporate banking business, provide liquidity to investor/clients for purposes of their own commercial business (unrelated to the acquisition of the institution’s own shares). This is carried out by providing loans pledged with financial collateral in the form of equity shares, corporate bonds, sovereign debt, term deposits or cash in a sight account. Under the contractual arrangements of the loan and the pledge, as well as applicable legal regulation in our jurisdiction, in the event of default of the obligor the institution is not allowed to foreclose the financial collateral. Instead, it is allowed to sell the collateral in the market and seize the proceeds. However, the institution is only allowed to sell collateral in the amount that is required settle the debt of the obligor, no more. Financial collateral is valued daily and therefore the institution can sell it in the market until the debt is settled in full. Accordingly, the amount of the synthetic holding should be the accounting value of the pledged shares limited by the limit of the EAD of the loan. We present below two scenarios where there is overcollateralization. Scenario 1 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of the institution’s own equity shares in the amount of 150 shares that are valued in the market 1 monetary unit each, for a total amount of 150 monetary units.  The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares to settle the debt and therefore the deduction should be the accounting value of 100 shares as per Q&A 2020_5128. Is the approach followed by the institution, correct? Scenario 2 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of: 100 shares of the institution own shares that are valued in the market 1 monetary unit each, for a total amount of 100 monetary units. 100 shares of another company, for the purpose of the scenario is an industrial company, that are valued at 1 monetary unit each, amounting a total of 100 monetary units. The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares in total and would sell in the market the obligor’s portfolio prorate, i.e. 50 shares of the institution and 50 shares of the shares of the industrial corporate. Accordingly, the deduction would be the accounting value of 50 shares of the institution, in line with Q&A 2020_5128. Is the approach followed by the institution, correct?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7586
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/11/2025

Deduction of pledged own shares from Common Equity Tier 1 items

Institutions, in the context of private banking and or corporate banking business, provide liquidity to investor/clients for purposes of their own commercial business (unrelated to the acquisition of the institution’s own shares). This is carried out by providing loans pledged with financial collateral in the form of equity shares, corporate bonds, sovereign debt, term deposits or cash in a sight account. Under the contractual arrangements of the loan and the pledge, as well as applicable legal regulation in our jurisdiction, in the event of default of the obligor the institution is not allowed to foreclose the financial collateral. Instead, it is allowed to sell the collateral in the market and seize the proceeds. However, the institution is only allowed to sell collateral in the amount that is required settle the debt of the obligor, no more. Financial collateral is valued daily and therefore the institution can sell it in the market until the debt is settled in full. Accordingly, the amount of the synthetic holding should be the accounting value of the pledged shares limited by the limit of the EAD of the loan. We present below two scenarios where there is overcollateralization. Scenario 1 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of the institution’s own equity shares in the amount of 150 shares that are valued in the market 1 monetary unit each, for a total amount of 150 monetary units.  The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares to settle the debt and therefore the deduction should be the accounting value of 100 shares as per Q&A 2020_5128. Is the approach followed by the institution, correct? Scenario 2 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of: 100 shares of the institution own shares that are valued in the market 1 monetary unit each, for a total amount of 100 monetary units. 100 shares of another company, for the purpose of the scenario is an industrial company, that are valued at 1 monetary unit each, amounting a total of 100 monetary units. The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares in total and would sell in the market the obligor’s portfolio prorate, i.e. 50 shares of the institution and 50 shares of the shares of the industrial corporate. Accordingly, the deduction would be the accounting value of 50 shares of the institution, in line with Q&A 2020_5128. Is the approach followed by the institution, correct?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7585
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/11/2025

Deduction of pledged own shares from Common Equity Tier 1 items

Institutions, in the context of private banking and or corporate banking business, provide liquidity to investor/clients for purposes of their own commercial business (unrelated to the acquisition of the institution’s own shares). This is carried out by providing loans pledged with financial collateral in the form of equity shares, corporate bonds, sovereign debt, term deposits or cash in a sight account. Under the contractual arrangements of the loan and the pledge, as well as applicable legal regulation in our jurisdiction, in the event of default of the obligor the institution is not allowed to foreclose the financial collateral. Instead, it is allowed to sell the collateral in the market and seize the proceeds. However, the institution is only allowed to sell collateral in the amount that is required settle the debt of the obligor, no more. Financial collateral is valued daily and therefore the institution can sell it in the market until the debt is settled in full. Accordingly, the amount of the synthetic holding should be the accounting value of the pledged shares limited by the limit of the EAD of the loan. We present below two scenarios where there is overcollateralization. Scenario 1 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of the institution’s own equity shares in the amount of 150 shares that are valued in the market 1 monetary unit each, for a total amount of 150 monetary units.  The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares to settle the debt and therefore the deduction should be the accounting value of 100 shares as per Q&A 2020_5128. Is the approach followed by the institution, correct? Scenario 2 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of: 100 shares of the institution own shares that are valued in the market 1 monetary unit each, for a total amount of 100 monetary units. 100 shares of another company, for the purpose of the scenario is an industrial company, that are valued at 1 monetary unit each, amounting a total of 100 monetary units. The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares in total and would sell in the market the obligor’s portfolio prorate, i.e. 50 shares of the institution and 50 shares of the shares of the industrial corporate. Accordingly, the deduction would be the accounting value of 50 shares of the institution, in line with Q&A 2020_5128. Is the approach followed by the institution, correct?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7584
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/11/2025

Umgang mit unwiderruflichen Zeichnungszusagen für Fondsanteile im Kreditrisiko Kurzbeschreibung: Zuordnung und Risikogewichtung von Zeichnungszusagen in den Phasen der Fondsauflegung

Im Rahmen der Abbildung unwiderruflicher Zeichnungszusagen für Fondsanteile in unserem Spezialfonds stellen sich uns folgende Fragen:1.    In welcher Forderungsklasse des Kreditrisikos nach 575/2013 der CRR (CIU gem. Art. 132 oder Unternehmen gem. Art. 122) sind unwiderrufliche Zeichnungszusagen während der Phase 3(Auflegung des Sondervermögens) sowie während der Phase 4 (nach Auflegung des Sondervermögens) zuzuordnen?2.    Mit welchem Risikogewicht sind diese Zusagen in den jeweiligen Phasen zu bewerten? 

  • 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: 2025_7582
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 02/12/2025

Requirements of Z 11.00 for RLE that are not institutions

Article 3 - Group resolution reporting  We observed some differences, especially for the Z 11.00 template when comparing the 2 parts of the final draft below: the draft proposal to the commission (chapter 3 Draft Implementing Technical Standards, article 3) and the tab in accompanying documents (chapter 2 Background and rationale - 2.2.4 Overview of revised reporting obligations). It seems there is no article requiring specifically from RLEs that are institutions to report Z 11.00 template, although it is included in the tab "Overview of revised reporting obligations". The Z 11.00 template is mentioned in paragraph 7, which seems to either concern the resolution entity or the scope of the article seems to be (too) large (all entities?). Could you please confirm whether Z11.00 template is required for RLE that are not institutions? Other information: In order to compare with Z02.00 requirements, paragraph 3 (a) specifically required Z 02.00 for RLE that are institutions.

  • 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: 2025_7581
  • Topic: Resolution plans
  • Date of submission:
  • Published as Rejected Q&A: 27/11/2025

The instructions for row 0170 C10.00 seem inconsistent.

The instructions for row 0170 C10.00 seem inconsistent. The title of the line item "Of which: categorised as secured by residential real estate in IRB" refers to secured by residential real estate. Whereas further instructions, "Exposures assigned under IRB approach to the exposure class 'Purchased receivables' pursuant to Article 147(2), point (d)(ii) of Regulation (EU) No 575/2013.", refers to Purchased recaivables. The article mentioned, 147(2)(d)(ii), refers to retail exposures secured by residential property.  Is our understanding correct that this row should not only be populated for Purchased receivables under the IRB approach but actually should be populated for secured by residential real estate under IRB approach?

  • 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: 2025_7579
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Presentation of lending for house purchase

Can loans that are directly disbursed to customers be considered as lending for house purchase?

  • 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 (repealed)
  • ID: 2025_7578
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Delimitation of the quantity of liabilities and capital instruments to be computed in the NSFR calculation

In the context of Article 428o(a) CRR, which lists liabilities and capital items subject to a 100% available stable funding (ASF) factor, how should the reference to “before the adjustments required pursuant to Articles 32 to 35, the deductions pursuant to Article 36 and the application of the exemptions and alternatives laid down in Articles 48, 49 and 79” be interpreted? Specifically, should: the Common Equity Tier 1 (CET1) items be included in full, before all adjustments, deductions and exemptions referred to in Articles 32 to 35, 36, 48, 49 and 79; or the CET1 items be taken before adjustments pursuant to Articles 32 to 35, but after the deductions defined in Article 36 and the exemptions and alternatives laid down in Articles 48, 49 and 79?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7577
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 10/11/2025

SPV repack transactions (collateral eligibility)

For recognising received financial collateral when calculating the exposure value under the counterparty credit risk (CCR) framework, does Article 207(2) CRR – which requires that the credit quality of the obligor and the value of the collateral shall not have a material positive correlation – apply?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7576
  • Topic: Market risk
  • Date of submission:

SPV repack transactions

Do SPV repackaging transaction on standardised platforms incur counterparty credit risk (CCR) or is the termination scenario considered a contractual feature that only results in market risk? If these transactions are subject to counterparty credit risk, how should the value of the collateral be taken into account?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7575
  • Topic: Market risk
  • Date of submission:

Calculation of dividend component at individual accounts of the institution

In the context of CRR article 314(2), should the dividend component (DC) at individual level include the dividends received from wholly owned subsidiaries?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7574
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

Validation rules taxonomy V4.0 C_17.01

Validation rule v23510_h incorrect

  • 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: 2025_7573
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Calculation rule

Please precise calculation rules for : number of transactions on proprietary accounts (column 0100) number of transactions on clients accounts (column 0110) Cumulated notional amount  (column 0140)

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans
  • ID: 2025_7572
  • Topic: Resolution plans
  • Date of submission:
  • Published as Rejected Q&A: 27/11/2025

Provide a detailed definition of the 'operator' of the FMI.

Please provide a detailed definition of the 'operator' of the FMI, and some examples.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans
  • ID: 2025_7570
  • Topic: Resolution plans
  • Date of submission:
  • Published as Rejected Q&A: 27/11/2025

Finrep validation between F09.01.1 and F18.00 other commitments given

If we have undrawn credit facilities that based on CRR Annex I are reported under Other commitments given in F18.00 r0480 c0010, but they do not meet any of the conditions described in Annex V Part 2.105 (a-c) to be reported in F09.01.1, we cannot report them on F09.01.1 but in F18.00 only.  Validation errors  v2795_m: [F 18.00.e, F 09.01.1] {F 18.00.e, r0480, c0010} = {F 09.01, r0170, c0010} + xsum({F 09.01.1, (r0170, c0010, c0020, c0030, c0035, c0100)}) and v2797_m: [F 18.00.e, F 09.01.1] {F 18.00.e, r0500, c0010} = {F 09.01, r0200, c0010} + xsum({F 09.01.1, (r0200, c0010, c0020, c0030, c0035, c0100)})  require that Other commitments given match in both these tables. What if the conditions mentioned in Annex V Part2.105 are not met for the other commitments given in F18.00?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7569
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 16/10/2025