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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.

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List of Q&A's

Unweighted delta sensitivities in template C91

In the C90 template on market risks - Alternative Standardised Approach Summary - the first two columns must show the unweighted sensitivities broken down by positive and negative aggregated by risk factor.Should positive and negative sensitivities be aggregated from net risk factor sensitivities or risk factor sensitivities for individual positions? 

  • 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_7001
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 23/02/2024

Treatment of inflows from credit facilities in LCR

Is a credit institution entitled to consider inflows from a credit facility in LCR, if the credit facility contractually expires within 30 calendar days and the client has no contractual option to prolong it beyond its current expiry date?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement
  • ID: 2024_7000
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 05/03/2024

Calculation of K-COH

Should the transactions relating to managing the delegated investment funds’ portfolios be included into COH of the investment firms?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_6999
  • Topic: K-factor requirements
  • Date of submission:
  • Published as Rejected Q&A: 26/04/2024

Direct and indirect applicability of DORA

Should a credit bureau apply DORA directly, similar to any other financial entity, as an Account Information Service Provider or AISP, or should the CRA apply DORA indirectly, as an ICT third-party provider?

  • Legal act: Directive 2022/2556/EU (DORA)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_6998
  • Topic: Other DORA topics
  • Date of submission:
  • Published as Rejected Q&A: 19/07/2024

Services of credit registers under DORA

Should public Credit Registers be regarded as providers of ICT services under Article 3(19) of DORA?

  • Legal act: Regulation (EU) No 2022/2554 (DORA)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_6997
  • Topic: Other DORA topics
  • Date of submission:
  • Published as Rejected Q&A: 19/07/2024

Services of credit bureaus under DORA

Do the services offered by credit bureaus fall within the definition of 'ICT services' as outlined in Article 3(21) of DORA? If so, can credit bureaus be considered as providers of ICT services under Article 3(19) of DORA?

  • Legal act: Directive 2022/2556/EU (DORA)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_6996
  • Topic: Other DORA topics
  • Date of submission:
  • Published as Rejected Q&A: 19/07/2024

Eligibility of funded credit protection received from third parties

Can cash collateral received from third parties via funded credit protection arrangements (i.e. funded guarantees or credit derivatives) qualify as collateral for the purposes of K-TCD and K-CON? 

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_6994
  • Topic: K-factor requirements
  • Date of submission:

Consideration of CDS on itraxx main and itraxx crossover as eligible hedges in SA-CVA

It is possible to consider the CDS on itraxx main and itraxx crossover as eligible hedges in SA-CVA without including the perimeter exceptions specified in aticle 382.4?

  • 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_6993
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 23/02/2024

Grace period for existing contractual arrangements in the register of information

As stated in Regulation (EU) No 2022/2554 (DORA) Article 28, paragraph 3 - As part of their ICT risk management framework, financial entities shall maintain and update at entity level, and at sub-consolidated and consolidated levels, a register of information in relation to all contractual arrangements on the use of ICT services provided by ICT third-party service providers. Is there a grace period for the existing contractual arrangements, or does all the information have to be collected and recorded in the register of information before the regulatory deadline in January 2025? 

  • Legal act: Regulation (EU) No 2022/2554 (DORA)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_6991
  • Topic: ICT third-party risk management
  • Date of submission:
  • Published as Rejected Q&A: 05/11/2024

Applying adjustments and deductions in Article 36 in full

In Article 48(2)(a) of Regulation (EU) No 575/2013 (CRR) it states: 'the residual amount of Common Equity Tier 1 items after applying the adjustments and deductions in Articles 32 to 36 in full and without applying the threshold exemptions specified in this Article;' Question: When applying the adjustments and deductions in Articles 32 to 36 in full should be deducted the value of deferred tax assets and significant investments?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_6990
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 05/03/2024

Criteria for selecting the operations to be included in the calculation of fraud rates for the transaction risk analysis (TRA) exemption

Which of the following would be the correct temporal criterion for selecting the unauthorized transactions to be included in the numerator of the fraud rates calculated for the transactions risk analysis (TRA) exemption? a) the transaction date, i.e., the date on which the transaction was executed regardless of the date on which it is classified as unauthorized or fraudulent b) the registration date, i.e., the date on which the transaction is registered as unauthorized or fraudulent regardless of the date on which it was carried out 

  • 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_6989
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 27/09/2024

Outflow of liquidity facilities provided to an SSPE

Based on article 31 (6) of the Delegated Regulation 2015/61 including amendments should the bank apply 10% outflow to an undrawn committed liquidity facility that has been provided to an SSPE for the purpose of enabling that SSPE to purchase mortgages from a financial customer?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement
  • ID: 2024_6988
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 07/08/2024

Template 2: Banking book - Climate change transition risk: Loans collateralised by immovable property - Energy efficiency of the collateral

The formula linked to the following rule IDs: v16049_m; v16078_m; v16080_m; v16082_m; v16084_m; v16086_m; v16088_m; v16090_m and v16092_m appears to be incorrect.

  • 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_6987
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 09/04/2024

clarification which EBA Q&A to apply: EBA Q&A 2017_3277 or EBA Q&A 2023_6791

clarification which EBA Q&A to apply: EBA Q&A 2017_3277 or EBA Q&A 2023_6791

  • 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_6985
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 04/03/2024

Qualification of a branch as originator, designation of Competent Authority and compliance with STS requirements

May a branch of a credit institution be considered as an entity within the meaning of Article 2.3 of the Regulation (EU) 2017/2402 and hence as originator under Article 29(5) thereto?  Should the answer to the above question be affirmative, which Competent Authority (home or host) should be responsible to supervise the STS requirements set out in Articles 18 to 27 of the Regulation (EU) 2017/2402?

  • Legal act: Regulation (EU) No 2017/2402 (SecReg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_6984
  • Topic: Other topics
  • Date of submission:

Template 2 - EBA val rules and Column 0160 Of which level of energy efficiency EP score in kWh_m of collateral estimate

Question 1: Are the validation rules v16092_m; v16090_m; v16088_m; v16086_m; v16084_m;v16082_m; v16080_m; v16078_m; v16049_m correctly defined?    Question 2:  How to deal with exposure for which and EPC is available, but the Level of energy efficiency (EP score in kWh/m² of collateral) is absent from the EPC?

  • 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_6983
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 26/04/2024

Can Taxonomy eligible but not aligned exposure be included into template 10 “Other climate change mitigating actions that are not covered in the EU Taxonomy”

Question 1: Should this template include ONLY exposure NOT eligible in the EU Taxonomy? OR can exposure eligible in the EU Taxonomy but not aligned be reported as well?   Question 2: supposed the answer for question 1 is: exposure eligible in the EU Taxonomy but not aligned can reported in template 10, can we derive that such exposure will be reported in both the GAR (because eligible and not aligned) and in the template 10?

  • 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_6982
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 13/02/2024

Assignment of a 0% risk weight to equity exposures to subsidiaries that are not institutions

Can a risk weight of 0% be assigned pursuant to Article 113(6) CRR to an equity exposure to a subsidiary which is not an institution, provided that all conditions in Article 113(6)(a) to (e) are met? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_6981
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 28/02/2024

Definition of "financial holding company"

Does a financial institution need to have multiple subsidiaries to meet the definition of a financial holding company?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_6980
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 01/02/2024

Clarification on How the Guidelines Impact Vendors Whose Products are Not Deemed as Outsourcing Arrangements

In light of the EBA's clarification(pages 88 and 89) we understand that the purchase of standardized/licensed software or services, such as those supporting IT platforms (e.g., web hosting, DDoS systems, data backup processes), does not fall within the scope of outsourcing (as per the EBA's response to related queries). Paragraphs 24 and 25 on page 11, however, require financial institutions to assess risks from third-party arrangements, even if not classified as outsourcing. As a vendor providing non-outsourcing arrangements, we seek clarification on whether the EBA requires financial institutions to mandate compliance with the EBA outsourcing guidelines in our case, considering our offerings are explicitly excluded from the outsourcing definition. Can financial institutions require compliance with these guidelines, citing them as a compulsory regulatory requirement, even when our offerings do not qualify as outsourcing arrangements? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2019/02 - Guidelines on outsourcing arrangements
  • ID: 2024_6979
  • Topic: Internal Governance
  • Date of submission:
  • Published as Rejected Q&A: 04/03/2024