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List of Q&A's

Exemption from approval for financial holding companies or mixed financial holding companies as per Directive 2013/36/EU (CRD) Article 21a (4) (d)

Should the criterion in Article 21a (4) (d) CRD (engagement in taking management, operational or financial decisions affecting the group or its subsidiaries) be considered to be met if the some persons are represented on the governing bodies of both the (mixed) financial holding company and an institution that is a subsidiary?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7330
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 03/03/2025

Reported amount in F09.02 col0010 if overcollateralization can occur

How should financial guarantees be reported in F09.02 if the value of the guarantee exceeds the loan exposure (possible overcollateralization)?Example:There is a credit risk mitigation group including 2 financial guarantees and 1 loan exposure as follows:Financial guarantee nr.1 - 15 000 EURFinancial guarantee nr.2 - 17 000 EURLoan exposure - 14 000 EURReported amount in F09.02 col0010 = ?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)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_7328
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 28/02/2025

Date of Disclosure

CRR Art. 433 states that the disclosure should happen the date of the publication of the financial statements. Due to the imlempentation of CRR III EBA granted an extention to submit Q1 regulatory reports to the 30.06. How should the disclosure be handled?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/11 - Guidelines on disclosure requirements under Part Eight of CRR
  • ID: 2025_7327
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 28/02/2025

Validation rules taxonomy V4.0 C08.01 v4770_m

The formula v4770_m specifies that for C08.01, the total sheet is the sum of all the IRB Foundation sheets, including the memorandum items.However, Final ITS instructions specify that memo subcategories must be reported separately as a subclass of exposure, not linked to the total IRB exposures classes. Also, in the C02.00, lines with reference to memorandum items are shaded and not included in the totalization.The control seems incoherent.Could you please therefore confirm that sheets with reference to memo items should be removed from the formula?

  • 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_7326
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 26/02/2025

Validation rules taxonomy V4.0 C08.01 v4769_m

The formula v4769_m specifies that for C08.01, the total sheet is the sum of all the IRB Advanced sheets, including the memorandum items.However, Final ITS instructions specify that memo subcategories must be reported separately as a subclass of exposure, not linked to the total IRB exposures classes. Also, in the C02.00, lines with reference to memorandum items are shaded and not included in the totalization.The control seems incoherent.Could you please therefore confirm that sheets  with reference to memo items should not be taken into account in the formula?

  • 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_7325
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 26/02/2025

Validation rules taxonomy V4.0 C09.02 v6052_m

According to the formulae v6052_m : {r0150} = {r0010} + {r0011} + {r0012} + {r0013} +{r0020} + {r0030} + {r0060} + {r0132} +{r0140} in c0010, c0030, c0040, c0050, c0055, c0060, c0070, c0105, c0110, c0120, c0125, c0130 in C09.02 “CR GB 2”.This control ensures that the sum of exposures declared in line 0150 "Total exposures" is equal to the sum of lines 0010 "Central governments or central banks", 0011 "Of which: Regional governments or local authorities", 0012 "Regional governments or local authorities", 0013 "Public sector entities", 0020 "Institutions", 0030 "Corporates", 0060 "Retail", 0132 "Collective investments undertakings (CIU)" and 00140 "Equity" in CR GB 2.However, the line 0011 is an "of which" of the line 0010 which is also in the formula, this means that it will be doubly taken into account in the totalization.Could you please therefore confirm that the line 0011 should be deleted from the formula?

  • 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_7324
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 26/02/2025

Validation rules taxonomy V4.0 C09.02 v23650_h

According to the formulae v23650_h : {r0030} = {r0050} + {r0051} in c0010, c0030, c0040, c0050, c0055, c0060, c0070, c0105, c0110, c0120, c0121, c0122, c0125, c0130 in C09.02 “CR GB 2”.This control makes the comparative between r0030 “Corporates” and the sum of lines r0050 “Of Which: SME” and r0051 “Of Which: Large Corporates" in CR GB 2.However, in Annex 2, the instructions for line 0030 refer to Article 147(2), point (c), of Regulation (EU) No 575/2013 which classifies Corporates as the following : i)General Corporate, ii) Specialized financing exposures and iii)Purchased receivables. The control seems incoherent since lines r0050 and r0051 expect "of which" items.To be compliant with the corporate categories defined in Article 147, line 0030 should be compared with the totalization of lines 0052 "Specialized lending", 0057 "Purchased receivables" and 0058 "Others".Could you please therefore confirm that the control needs to be modified?

  • 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_7323
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 26/02/2025

Classification as a “specialised debt restructurer” (SDR) pursuant to Article 36(5) of Regulation No 575/2013

To be classified as specialised debt restructurer in accordance with Article 36(5) of the Regulation No 575/2013 (CRR), an institution’s sight deposits must not exceed 5% of its total liabilities. How should the term “sight deposits” be interpreted in the context of the Article 36(5) of the CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7322
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 20/03/2025

Classification as a “specialised debt restructurer” (SDR) pursuant to Article 36(5) of Regulation No 575/2013

For how long prior to an institution’s classification as a specialised debt restructurer must all criteria specified in Article 36(5) of Regulation No 575/2013 be met by the institution?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7321
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 20/03/2025

EBA_v10862 (Type – Warning validation): Assets under custody ({G01.00,r0060,c0010}) should be equal to the value in FINREP ({F22.02,r0060,c0010}).

a) The “Custody assets” referred in FINREP 22.2 is described as “service of safekeeping & administration of financial instruments for the account of clients provided by the institution and services related to custodianship such as cash and collateral management”. How the word “Service” in above definition needs to be interpreted? Does it mean to populate balance only in those cases where some fee is being charged for services provided or record all custody assets irrespective of any fee is charged /revenue being generated? 21.2. Assets involved in the services provided (22.2)285. Business related to asset management, custody functions, and otherservices provided by the institution shall be reported using the followingdefinitions:(a) ‘Asset management’ shall refer to assets belonging directly to thecustomers, for which the institution is providing management. ‘Assetmanagement’ shall be reported by type of customer: collective investmentundertakings, pension funds, customer portfolios managed on adiscretionary basis, and other investment vehicles;(b) ‘Custody assets’ shall refer to the services of safekeeping andadministration of financial instruments for the account of clients providedby the institution and services related to custodianship such as cash andcollateral management. ‘Custody assets’ shall be reported by type ofcustomers for which the institution is holding the assets distinguishingbetween collective investment undertakings and others. The item ‘of which:entrusted to other entities’ shall refer to the amount of assets included incustody assets for which the institution has given the effective custody toother entities; b)    As the validation rule “V10862" matches 2 data points (AUM and Custody assets) which in GSIB is reported in one cell under table G01.00 Row 0060 “Assets under Custody” whereas in FINREP table 22.2 there are two different cells representing it “Assets Management(by type of customer) Row 0010” & “Custody assets (by type of customer) Row 0060” , thus making the validation incorrect? Hence, please clarify as to how to interpret the validation and whether it will be updated to include Asset Management and Custody Assets in FINREP 22.2 (i.e. validation will be Asset Management + Custody Assets in FINREP 22.2 to "Assets Under Custody" in GSIB) such that the number then reported will tie back with GSIB "Assets under custody”.

  • 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_7320
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 28/02/2025

Period to comply with the limit referred to in Article 37 regarding concentration risk and exposure value excess.

What limit does it refer Art. 38 (2) when it states that “Competent authorities may grant the investment firm a limited period to comply with the limit referred to in Article 37”? 

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7319
  • Topic: Concentration risk
  • Date of submission:
  • Published as Rejected Q&A: 19/03/2025

CCF of items (b) and (c) of bucket 5 from 2025 to 2032

Which credit conversion factor shall be applied to the undrawn amount of retail credit lines for which the terms permit the institution to cancel them to the full extent allowable under consumer protection and related legal acts (item listed in point (b) of bucket 5), and to undrawn credit facilities for tender and performance guarantees which may be cancelled unconditionally at any time without prior notice, or that do effectively provide for automatic cancellation due to deterioration in a borrower’s creditworthiness (item listed in point (c) of bucket 5) in the years 2025 to 2032?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7318
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 23/04/2025

Counterparty classification of CCP

Where counterparty sector breakdown applies, it is required more guidance on how to classify a CCP which have the banking license. For instance, in template F10, where should we report derivatives positions we have with a QCCP which at the same time is (i) a clearing house and (ii) a credit institution (included in the list of ECB’s supervised banks)? We face the ambiguity in classification in further reporting frameworks both supranational (e.g. G-SIB data collection exercise, FSB)  and local (i.e. Circolare 262 Banca d’Italia on Financial Statements).

  • 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_7316
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/03/2025

RWA in COREP C43

In COREP C43, which RWA should be reported? In particular, should RWA be reported with or without taking into account the derogations (transitional measures) impacting RWA in CRR3?

  • 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_7315
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as Rejected Q&A: 28/04/2025

C01.00 - CIU deduction from own funds

Where in the sheet C01.00 of the COREP, can we deduct CIUs under fallback approach (subject to 1250% RWA) from CET1 (as permitted by article 36.1.k.vi) since no dedicated caption is currently foreseen?

  • 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_7314
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 21/03/2025

Part 2 – Template specific instructions to template B_06.01

Data point B_06.01.0050 is missing from the official ITS templates. Is this data point no longer applicable?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information
  • ID: 2025_7313
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as final Q&A: 28/03/2025

DPM 400 - Modelisation of report C1000

we have a suspicion of schizophrenic modeling on the new C1000 report.  Indeed on this report when we look at the annotated templates it seems that all cells from column 0090 are sharing the same XBRL address as their corresponding cell for the same row from column 0100. Which means that from a technical point of view we will only be able to submit one “amount” per pair of cells C0090/C0100 for a dedicated row. For instance the Annotated templates stats that : {C_10.00, r0060, c 0090, s0000}=={C_10.00, r0060, c 0100, s0000} VariableID 3295841 VariableVID = 3295841    In the same time when we look at the ITS : We understand that may be possible that the transitional provisions do not apply  and so that or instance amount reported in cell 0020 _ 0090 can be equal to the amount in cell  0020 _ 0100 where the amount expected  for both cell is zero.  But we do expect from our understanding of the ITS that the transitional provision may apply and that the impact should be reported in various rows. In this case we will need to report different amounts on a specific row for those two columns, which seems unfeasible with the current setting.   Do you agree with our understanding?    

  • 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_7312
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 21/03/2025

Regulatory technical standards - subcontracting ICT services supporting critical or important functions

Where and when was the Comission Delegated Regulation (EU) supplementing Regulation (EU) 2022/2554 of the European Parliament and of the Council with regard to regulatory technical standards to specify the elements which a financial entity needs to determine and assess when subcontracting ICT services supporting critical or important functions as mandated by Article 30(5) of Regulation (EU) 2022/2554 oficially published? 

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7310
  • Topic: Other DORA topics
  • Date of submission:
  • Published as Rejected Q&A: 17/03/2025

Validation rule v22095_h in Reporting Framework 3.5

The question concerns the EBA Reporting Framework 3.5, Validation Rules (19 December 2024), rule v22095_h. This rule require that total amounts of Loans and Advances should be equal to the sum of sub-total amounts (Retail, Wholesale non-financial, Wholesale financial) in the context of Reporting on interest rate risk in the banking (specified in Section 12 – ‘Reporting on interest rate risk in the banking book’ of Annex I to Regulation (EU) 2024/3117, form J02.00 : {r0050} = +{r0080} + {r0100} + {r0110}Is the formula correct having in mind the possibility to have exposures from clients that do not satisfy definitions of sub-categories but have to be reported in "Loans and Advances"? 

  • 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_7308
  • Topic: Supervisory reporting - IRRBB
  • Date of submission:
  • Published as Rejected Q&A: 28/04/2025

Computation of the secured part of Non-IPRE according to Art.125(1)

In the computation of the secured part of Non-IPRE exposures, should senior liens from banks within the same group be taken into account?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7305
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 21/02/2025