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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

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

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

The final answer to EBA Q&A 2023_6962 states that when capping the exposure value of a margined netting set at the exposure value of the same netting set not subject to any form of margin agreement “The term NICA, included in the formula set out in Article 275(1) and defined in Article 272(12a), does not include the variation margin posted or received.”   We believe that this is an incorrect reading and could lead to significant under estimation of RWAs whenever the institution is posting significant excess collateral to its client. This can happen particularly when trades with a large MTM unwind at maturity and the collateral balance is exchange back only on T+1 basis.   Take the following example scenario. If calculating the EAD per the margined methodology the variation margin posted to the client offsets some of the MTM of the derivatives and the add-on is fully added to EAD as the multiplier remains 1.    However under the unmargined methodology if I disregard the posted collateral then the negative current replacement cost works to significantly offset the add-on and can actually result in an EAD below the EAD incurred on only the actual replacement cost/current exposure (in this example 140).   Example Scenario       MTM of Derivatives -50 Variation Margin posted to client 150 Replacement Cost (Margined) 100 Add-on (pre multiplier) 100 Multiplier 1 EAD per margined methodology 280     MTM of Derivatives -50 Variation Margin posted to client (ignored as not NICA) 0 Replacement Cost (Unmargined ignoring VM posted) 0 Add-on (pre multiplier) 100 Multiplier 0.78 EAD per unmargined methodology 109     Final capped EAD to unmargined 109   Our understanding is that the wording in Article 274(3) which says “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” instead of meaning that there is no variation margin and hence this should be completely removed in the unmargined cap calculation should actually be read in conjunction with Article 272(12a) to define that in the absence of a margin agreement there can be nothing classed as “variation margin” and therefore all collateral is part of NICA – “NICA means the sum of the volatility-adjusted value of net collateral received or posted, as applicable, to the netting set other than variation margin”.   If we follow the previous Q&A answer then we will see significant reductions in RWA which we feel are unwarranted vs the counterparty risk for netting sets which exhibit the same portfolio dynamic as in the example above. The purpose of the cap is only to ignore exposure from large threshold amounts and not to avoid exposure from large amounts of posted collateral which are still owed back 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7109
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 23/10/2024

Counting of days past due in factoring arrangements.

As for non-recourse factoring, is it correct to start the counting of days past due based on the payment schedule defined or implied in the contractual terms with the client (i.e., the party from which the factor purchases the receivables)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/07 - Guidelines on the application of the definition of default under Article 178 CRR
  • ID: 2024_7108
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2024

Operational risk – gross loss in tax related events in accordance with REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) No 575/2013 as regards requirements for credit risk, credit valuation adjustment risk, operational risk, market risk and the output floor, Article 318.

How should an institution calculate gross loss based on the regulatory changes stipulated in Article 318. of the Regulation amending Regulation 575/2013 in the following examples? Case 1 – Delayed tax payment, penalty interest payment, and system repairment expenses Case 2 – Delayed tax payment, no penalty interest payment, system repairment expenses.  Case 3 – Tax to be paid for this year and previous years, no penalty interest, or fine, financial reports for previous year to be revised and re-published.  Case 4 – Tax to be paid for this year and previous years, no penalty interest or fine, no changes to financial reports for previous year.  Case 5 – Tax to be paid for this year and previous years, penalty interest and fine, financial reports for previous year to be revised and re-published Case 6 – Tax to be paid for this year and previous years, penalty interest and fine, no changes to financial reports for previous year   

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7107
  • Topic: Operational risk
  • Date of submission:
  • Published as final Q&A: 11/04/2025

Fair value hierarchy: Financial instruments at fair value (F14)

Can you provide more guidance on the amounts to be reported for “Change in fair value for the period” and “Accumulated change in fair value before taxes” in particular for derivatives falling under netting agreement and recognized with accounting offsetting?

  • 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: 2024_7105
  • Topic: Supervisory reporting
  • Date of submission:
  • Published as final Q&A: 14/03/2025

LCR Treatment of Cancelled Term Deposit with Non-Financial Customers

Should time deposits from non-financial customers, which have been cancelled and fall due within 30 days, be multiplied by 40% as per Delegated Regulation 2015/61 Article 28(1)? Assuming these deposits don't meet the criteria for Delegated Regulation 2015/61 Article 27. This seems to provide a favorable treatment for time deposits which have been cancelled and fall within 30 days for non-financial customers (40%), where as those for retail and financial customers would be multiplied by 100% outflow rate. 

  • 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_7104
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 21/01/2025

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:
  • Published as final Q&A: 27/09/2024

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

Treatment of lease commitments from operate-lease contracts in supervisory reportings

Gemäß Art. 5 Abs. 1 CRR sind Risikopositionen als Aktivposten (Vermögenswert) oder außerbilanzieller Posten definiert. Bedeutet dies im Umkehrschluss, dass Leasingzusagen für Operate-Lease-Verträge nicht in den aufsichtsrechtlichen CRR-Meldungen auszuweisen sind, da diese nach nationalen Bilanzierungsregeln (HGB) nicht als außerbilanzieller Posten unter dem Bilanzstrich auszuweisen sind? According to Article 5 (1) CRR, risk positions are defined as an asset or off-balance sheet item. Conversely, does this mean that lease commitments for operate-lease contracts are not to be shown in supervisory CRR reportings, as these are not to be reported as off-balance sheet items below the balance sheet line under national accounting rules (HGB)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7101
  • Topic: Supervisory reporting
  • Date of submission:
  • Published as Rejected Q&A: 05/02/2025

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

What should be presented as “Loan commitments, financial guarantees and other commitments received” in F 09.02?

  • 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: 2024_7099
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 20/12/2024

Scope of Register of Information for Contractual Arrangements on the use of ICT Services Provided by ICT Third-party Service Providers

According to Article 28(3) of DORA, must an EU parent bank, which has subsidiaries both within and outside the EU, maintain the register of information regarding all contractual arrangements for the use of ICT services only for subsidiaries that are subject to DORA (financial entities established in the EU), or does this requirement extend to subsidiaries established outside the EU for which DORA does not apply?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7098
  • Topic: ICT third-party risk management
  • 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

Exemption for Non-EU ICT Intra-group Service Providers

Is it accurate to interpret that an ICT intra-group service provider established outside the EU (non-EU country), providing critical services to an EU-based financial institution (parent undertaking), falls within the exemption outlined in Article 31(8) of DORA, thereby exempting the need for establishing a subsidiary within the EU?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7096
  • Topic: Oversight framework of CTPPs
  • Date of submission:
  • Published as final Q&A: 11/12/2024

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

Definition of weighted average maturity (WAM) and weighted average yield (WAY)

Can you please confirm that the WAM is based on the residual time to maturity according to the contractual conditions? Furthermore which notional amount shall be used for averaging: the notional amount at reporting date or future notional amount including any amortization payment? If we base the calculation of the  WAM on the residual maturity, wouldn’t we – for consistency reason also the yield to maturity to be reported under WAY?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2022/14 - Guidelines on interest rate risk arising from non-trading book activities
  • ID: 2024_7094
  • Topic: Supervisory reporting - IRRBB
  • Date of submission:
  • Published as Rejected Q&A: 12/12/2024

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

Consistency of Article 447(f) CRR and ITS on public disclosures with the mapping tool for the key metric LCR in KM1

It is clear in article 447(f) of Regulation (EU) N0 575/2013 (CRR) and in the ITS on public disclosures by institutions under Part Eight of Regulation (EU) N0 575/2013 (annex II of Regulation (EU) 2021/637) that average LCR should be reported in KM1 (as well as average of liquidity buffer, outflows and inflows). However, in the mapping tool the references to the LCR numbers in KM1 are to LCR numbers in templates C72, C73, C74 and C76, which are the templates where the regular LCR is reported. The weighted average numbers for LCR are found in template LIQ1. So what is correct and what should be reported in KM1?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR
  • ID: 2024_7092
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 20/12/2024

Legal persons to whom the requirement to comply with reporting requirements under Article 54 of the IFR on a consolidated basis applies.

In case Article 7(1) of the IFR applies, does the requirement to comply with the reporting requirements under Article 54 of the IFR rest exclusively on either a Union parent investment firm, Union parent investment holding company or Union parent mixed financial holding company?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/2284 - ITS on Reporting and disclosures of Investment firms
  • ID: 2024_7091
  • Topic: K-factor requirements
  • Date of submission:
  • Published as final Q&A: 13/12/2024