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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

Loans collateralized by immovable property in F 05.01 and F 13.01

Do loans collateralized by immovable property in templates FINREP 05.01 and FINREP 13.01 need to comply with Articles 124 - 126 of the CRR?

  • 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_7510
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 18/07/2025

Credit Conversion Factor Treatment - Loan Participation Agreements in Unconditionally Cancellable Facilities

For loan participation arrangements where Bank A (the issuing bank) originates loans classified as unconditionally cancellable and applies 0% Credit Conversion Factor (CCF) under CRR Article 111, what is the appropriate CCF treatment for Bank B as the participating bank?Specifically, should Bank B apply:- a 0% CCF - consistent with the unconditionally cancellable nature of the underlying loans issued by Bank A- Standard CCF rates (20% or higher) - based on the participation agreement structure, where Bank B cannot directly exercise the unconditional cancellation rights?

  • 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: 2025_7505
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2025

EBA Mapping Tool Clarification - EU OV1 & EU CMS1

With regards to the mapping logic used for EU OV1 & EU CMS1, in particularly for the Market Risk related rows, these currently reference the new FRTB related reporting templates with the C 90 series. As the implementation of FRTB is set to be delayed by a further year (refer to communication from the European Commission) until 1st January 2027, we believe that the mapping logic should be updated to reflect, referencing back to the pre-CRR3 Market Risk templates C18.00-C24.00, in addition to C02.00. In addition, we feel that in relation to EU OV1 template, the rows associated to Market Risk may require amendment to reflect the pre-CRR3 breakdown, unless the interim requirement is to mirror the approach to the of reporting (in C02.00), where data is reported under the Simplified standardised approach (S-SA) only.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7504
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 21/08/2025

P3 Frequency of disclosure (Transparency and Pillar 3 | European Banking Authority) for reporting date 30-06-2025

When checking the P3 Frequency of disclosure table (Transparency and Pillar 3 | European Banking Authority) for reporting date 30-06-2025 we noticed that according to P3 Frequency of disclosure table (excel row 145_Disclosures on MREL/TLAC - Templates_with relevant article 15 with regard to the public disclosure of the minimum requirement for own funds and eligible liabilitie and point (a) of Article 437a, in accordance with 434a of CRR) bank "ABC" as "Large institutions (Listed and No GSII)" should publish P3-disclosure related to point (a) of Article 437a, in accordance with 434a of CRR on a semi-annual basis. However, according to the article 15 of ITS with regard to the public disclosure of the minimum requirement for own funds and eligible liabilities only institutions, that are G-SIIs or part of a G-SII and entities that are material subsidiaries of non- EU G-SIIs and that are not themselves resolution entities (subject to article to CRR Article 92a or 92b) shall make the disclosures set out in point (a) of Article 437a. So, we are experiencing some inconsistency between these 2 sources:  P3 Frequency of disclosure table (Transparency and Pillar 3 | European Banking Authority) vs article 15 of ITS with regard to the public disclosure of the minimum requirement for own funds and eligible liabilities.  As mentioned above, bank "ABC" is identified as “Large institutions (Listed and no G-SII)” and does not meet the above-mentioned requirement of article 15 of ITS with regard to the public disclosure of the minimum requirement for own funds and eligible liabilities only institutions and CRR article 437a as the bank is a ‘No G-SII’ entity. So, our initial conclusion is that bank "ABC" does not need to disclose information as set out in point (a) of Article 437a, in accordance with 434a of CRR on a semi-annual basis.  But in the above-mentioned P3 Frequency of disclosure table (Transparency and Pillar 3 | European Banking Authority) it does indicate that LARGE INSTITUTIONS (LISTED AND NO GSII), which bank "ABC" is, should provide information as set out in point (a) of Article 437a, in accordance with 434a of CRR on a semi-annual basis. Now, this caused us a little bit confusion and we are trying to find supporting regulations to verify the obligation for “Large institutions (Listed and no G-SII)” to provide information as set out in point (a) of Article 437a, in accordance with 434a of CRR on a semi-annual basis. Based on item 5a of article 9 ITS with regard to the public disclosure of the minimum requirement for own funds and eligible liabilities only institutions we noticed that large institutions (so applicable for bank "ABC") are required to provide disclosures as referred to in Article 15, while Article 15 also describes that only entities that are subject to  Article 92a or 92b shall disclose information as set out in point (a) of Article 437a, in accordance with 434a of CRR on a semi-annual basis. So, our questions are: Should we read “Disclosures referred to in Article 15’ as mentioned in item 5a of article 9 ITS with regard to the public disclosure of the minimum requirement for own funds and eligible liabilities only institutions as “Disclosure of main features of own funds and eligible liabilities” and ignore the remaining part as this is not meant as “disclosure”? Is dVB as LARGE INSTITUTIONS (LISTED AND NO GSII) obliged to provide information as set out in point (a) of Article 437a, in accordance with 434a of CRR on a semi-annual basis as prescribed in EBA’s template “Frequency of disclosures”? If bank "ABC" is obliged to disclose this on semi-annual basis, do we a have the choice to either disclose this qualitatively or quantitively by voluntarily providing both templates TLAC1 and TLAC3b, which are not required for LARGE INSTITUTIONS (LISTED AND NO GSII) on semi-annual basis, as the information as set out in point (a) of Article 437a, in accordance with 434a of CRR are already captured and included in these 2 existing templates? In EBA’s template “Frequency of disclosures” it is not precisely described how banks should disclose that. It does only mention that bank should provide information as set out in point (a) of Article 437a.     

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/763 – ITS with regard to the supervisory reporting and public disclosure of MREL
  • ID: 2025_7499
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 26/09/2025

Data quality scans and connected data corrections as model changes

Has the implementation of data quality scans to be treated as a change of a rating system in accordance with art 142 I CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7497
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 01/09/2025

EBA Mapping Tool Clarification - EU LIQ2

The EBA Mapping Tool logic in relation to EU LIQ2 does not appear to capture the 'Weighted Value' component. The current logic is as follows: {C 81.00, r0150, c0100} + {C 81.00, r0280, c0100}

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7496
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 21/08/2025

Clarification Request on Eligibility of Agricultural Land and Forests as Collateral for RWA Purposes under CRR

Dear Sir/Madam, We are seeking clarification regarding recent changes introduced by the EBA concerning the eligibility of agricultural land and forests as collateral for the purposes of calculating Risk-Weighted Assets (RWA) under the CRR framework. According to the updated EBA interpretation, agricultural land and forest land may be treated as eligible collateral, provided they are insured. However, in Croatia, insurance coverage exists only for crops—not for the land itself. This creates a significant implementation challenge, particularly for forest land, which does not contain insurable crops at all, making it impossible to obtain the required insurance. In light of this, we kindly request clarification on the following points: Can agricultural or forest land be treated as eligible collateral under CRR if the required insurance cannot be obtained due to a lack of available insurance products in the local market? Does the absence of crop-related insurance for forest land entirely preclude its recognition as eligible collateral, even if it meets all other requirements (e.g. enforceability, valuation, and monitoring)? How should institutions proceed when collateral types are deemed eligible by the EBA but cannot be insured in practice due to market limitations? Is there flexibility within the CRR framework to accommodate cases where key eligibility conditions (such as insurance) are not achievable despite best efforts, or are alternative treatments available for such exposures? We would appreciate your guidance and any references to applicable CRR articles or relevant EBA Q&A that may clarify how to proceed in such cases.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 183/2014 - RTS for the calculation of specific and general credit risk adjustments
  • ID: 2025_7495
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 01/09/2025

Discretionary pension benefits

According to Section 151 of the EBA Guidelines on sound remuneration policies under CRD (EBA/GL/2021/04) (“EBA Guidelines”), pension benefits that are not performance-based and are consistently granted to a category of staff as part of the company’s pension scheme should be regarded as routine employment packages. How should the concept of a “company’s pension scheme,” as referred to in Section 151 of the EBA Guidelines, be interpreted? For instance, can an established and consistently applied long-term practice qualify as a pension scheme, even in the absence of a formal written policy or documented scheme? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/04 - Guidelines on sound remuneration policies under CRD (repealing EBA/GL/2015/22)
  • ID: 2025_7494
  • Topic: Remuneration
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

Discretionary pension benefits

According to Section 151 of the EBA Guidelines on sound remuneration policies under CRD, EBA/GL/2021/04 (“EBA Guidelines”), pension benefits included in the company’s pension scheme that are not based on performance and that are consistently granted to a category of staff should be considered as part of routine employment packages.  What is the minimum number of persons that can form a category of staff in the meaning of the aforementioned Section? For example, can the Chief Executive Officer and Deputy Chief Executive Officer of an institution together (i.e. two persons) be considered “a category of staff” in the meaning of Section 151 of the EBA Guidelines? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/04 - Guidelines on sound remuneration policies under CRD (repealing EBA/GL/2015/22)
  • ID: 2025_7493
  • Topic: Remuneration
  • Date of submission:
  • Published as final Q&A: 01/08/2025

Discretionary pension benefits

Proportionate regular pension contributions on top of the mandatory regime are cited as an example of routine employment packages in the definitions section of the EBA Guidelines on sound remuneration policies under CRD (EBA/GL/2021/04) (“EBA Guidelines”). How large may such annual pension contributions be — whether in monetary terms or as a percentage of the staff member’s total annual remuneration — for the benefit to be considered proportionate and, provided that other criteria are met, qualify as a routine employment package (and therefore as fixed remuneration)? Does the size or other characteristics of the institution influence the assessment of whether a pension benefit is proportionate or routine? More broadly, what factors typically affect this assessment — for instance, do national industry-level remuneration benchmarks or the remuneration level within a specific institution play a role?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/04 - Guidelines on sound remuneration policies under CRD (repealing EBA/GL/2015/22)
  • ID: 2025_7492
  • Topic: Remuneration
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

Risk weighting attributed to gold in the form of a commodity such as jewellery items for pawn credit business

Pursuant to the new definition of gold bullion under Article 4(1)(60a) of CRR, can gold in the form of jewelry items taken as collateral in a pawn loan qualify as "gold" and thus be eligible for prudential treatment in accordance with Article 134 CRR for the value based on the gold content (purity × mass), with no allowance for artistic, numismatic, branding or other extrinsic attributes to such jewelry?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7491
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 01/09/2025

C13.01 Securitisation Template & Instructions - Incorrect References

In the final EBA CRR 3 policy paper it seems like the below text (465(7)) has moved to para 465(13) concerning the derogation from Article 92(5). Reporting instructions should be updated to change the reference in the COREP instructions and C13.01 template from para 7 to 13.

  • 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_7490
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 26/09/2025

EBA Mapping Tool Clarification - EU CR5

For last Column aa – the mapping prescribed by EBA is ‘col z - {C 07.00, sum of rows [from 140 to 280], c 230, s0002}’ which means: •    Col z (i.e. sum of all the exposure value under different RW) •    C7:o    sum of rows [from 140 to 280] = sum of all RW% o    C230 in C7 = which ‘RISK WEIGHTED EXPOSURE AMOUNT OF WHICH:  WITH A CREDIT ASSESSMENT BY A NOMINATED ECAI’  Our question is why we use exposure value minus RWA with a ECAI assessment? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7488
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 21/08/2025

EBA Mapping Tool Clarification - EU CQ4

We believe that the mapping logic applied to EU CQ4 is incorrect for the following: For EU CQ4, r010, col a - Mapping is "'{F 20.04, sum(r0080, r0140), c0010} - {F20.04, sum(r0080, r0140), c0011}", however, F20.04, r010,r040, r0075 are excluded For EU CQ4, r010, col b - Mapping is "{F 20.04, sum(r0080, r0140), c0025}", however, F20.04, r010,r040, r0075 are excluded For EU CQ4, r010, col c - Mapping is "'{F 20.04, sum(r0080, r0140), c0026}", however, F20.04, r010,r040, r0075 are excluded For EU CQ4, r010, col d - Mapping is "{F 20.04, sum(r0080, r0140), c0012}", however, F20.04, r010,r040, r0075 are excluded For EU CQ4, r010, col e - Mapping is "{F 20.04, sum(r0080, r0140), c0031}", however, F20.04, r010,r040, r0075 are excluded For EU CQ4, r010, col g - Mapping is "{F 20.04, sum(r0080, r0140), c0040}", however, F20.04, r010,r040, r0075 are excluded

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7487
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 21/08/2025

EBA Mapping Tool Clarification - EU CMS1 (2)

For CCR (Row2) within CMS1 - how would we capture SA IMM for S-TREA?  As the mapping in Column d/ EUd only capture S-TREA under IRB approach but nothing for exposure with SA IMM (which is also needed to recalculate to S-TREA).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7486
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 21/08/2025

EBA Mapping Tool Clarification - EU OV1

‘Template C 02.00, row 690 et seq.: according to the mapping tool for CRR3_step1 provided within the consultation on public disclosure (EBA/CP/2023/38) this row is mapped to the template OV1, row 1 “credit risk”. To our understanding additional “other risk exposure amounts” reported in row 690 et seq. could arise from all kinds of risk categories and are not limited to credit risk. More guidance about what is to be reported in row 690 et. seq. is needed, especially what is to be reported in row 760.’ 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7485
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 21/08/2025

EBA Pillar 3 Mapping Tool Clarification - EU CMS1

1. CMS1 R8/Col b mapping: [OV1, row 29, column a} - {CMS1, row 8, column a}: We are using OV1 R29a as TREA and then deducted the IM RWA from CMS1 to get the SA RWA.   2. CMS1 R7/ Col b: The mapping is a balance from R8, deducted R1-7; in that case – ‘amounts below the thresholds for deduction (row 25 in Template OV1)’ will be missing from R7 given that’s not include in the TREA (this line item was mentioned in the CMS1 instruction)

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7484
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 21/08/2025

SCA exception for Contactless only terminals (SoftPOS) in case of emergency

We are in the process of developing a backup solution for our SoftPOS terminal application, intended for use during exceptional circumstances such as cyber-attacks or other disruptions to internet connectivity and acquirer systems. As SoftPOS terminals operate exclusively with contactless transactions, and contactless transactions does not support Offline PIN, it is technically not possible to perform Strong Customer Authentication (SCA) in offline mode. We would like to confirm whether, under these conditions, it is acceptable to process offline contactless transactions without applying SCA and follow Directive (EU) 2015/2366 article 0 (15)

  • 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: 2025_7482
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:

Determination of exposure value cap for netting sets subject to a margin agreement.

Article 274(3) states "The exposure value of a netting set that is subject to a contractual margin agreement shall be capped at the exposure value of the same netting set not subject to any form of margin agreement". This wording has slightly diverged from Basel CRE52.2 which stated "The EAD for a margined netting set is capped at the EAD of the same netting set calculated on an unmargined basis".  Basel focused on applying the unmargined methodology in the wording not that it should be treated as if there were no margin agreement. This nuance in wording is leading to a misinterpretation of the CRR which is exacerbated by EBA Q&A 2023_6962 which has allowed for firms to apply SA-CCR in a manner which significantly underestimates capital requirements vs economic exposure. In situations where firms are posting excess variation margin which has a real economic credit risk to the counterparty the wording of the CRR and the Q&A implies that this can be fully disregarded from the exposure calculation. This would therefore mean that firms are able to arbitrage the capital rules and avoid capital charges by lending money to counterparties by posting it as variation margin under a CSA and then disregarding that exposure by applying the "unmargined" cap. This needs to be resolved by a clarification to the EBA Q&A to the effect that any collateral posted/received under a variation margin CSA should still be included in the exposure calculation, albeit using the unmargined rather than margined formulation to achieve the effect that the cap is designed to do per Basel CRE52.2 FAQ1.  i.e. this could easily be interpreted that if you are not subject to a margin agreement then anything which was variation margin should now just be characterized as NICA as it still economically exists as collateral. This would satisfy both the purpose of the rule and avoid the risk of understatement of capital requirements.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7478
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

EBA Mapping Tool - Template EU CC1 Logic

The EBA Mapping Tool that specifies the mapping of the templates and tables for disclosures with those on supervisory reporting is incorrect for Template EU CC1, r57 (Column a).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7477
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 21/08/2025