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List of Q&A's

Clarification of ETV calculation for mortgages securing more than one exposure

Article 124 paragraph 6 Regulation (EU) No 575/2013 (CRR) specifies the calculation of ETV for IPRE exposures. In order to calculate ETV, the gross value of an exposure should be divided by the value of property. Additionally, this article clarifies that: “For the purposes of the first subparagraph, point (a), where an institution has more than one exposure secured by the same immovable property and those exposures are secured by liens on that immovable property that are sequential in ranking order without any lien held by a third party ranking in-between, the exposures shall be treated as a single combined exposure and the gross exposure amounts for the individual exposures shall be summed up to calculate the gross exposure amount for the single combined exposure.” Our question refers to calculation ETV for joint mortgages – so the mortgage which secures more than one exposures and additionally these exposures may have other mortgages assigned. Based on the above, it’s clear that numerator should include the gross value of all exposures secured by this joint mortgage. Nevertheless, it’s unclear which value should be used in the denominator of ETV in the real life example described below.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7922
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 06/07/2026

Definition of "main business" under CRR

How are banks to interpret the concept of "main business" in Article 411(1) of Regulation (EU) No 575/2013 (CRR), read in conjunction with Annex I of Directive 2013/36/EU and Article 3(9) of Commission Delegated Regulation (EU) 2015/61? In particular: can an entity be considered to perform Annex I CRD activities as its "main business" within the meaning of Article 411(1) CRR if: there is an absence of any third-party commercial activity i.e. entity does not offer financial services to any external party for commercial consideration nature of the entity’s operations is ancillary to the group and it exists solely as an instrument of the group's non-financial operations with no independent commercial purpose

  • 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: 2026_7921
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 06/07/2026

Reporting obligations under Article 3 of the CIR

Whether, and to what extent, will the reporting obligations concerning Relevant Legal Entities (RLEs) under Article 3 of the CIR also apply where a recently acquired RLE is expected, with a high degree of certainty, to cease to exist as a legal entity prior to the adoption of the resolution plan as a result of a legal merger. Additionally, how should this acquired entity be treated for the purposes of resolution planning and related reporting obligations during the interim period between its acquisition and its absorption through merger? We wonder if resolution authorities (RAs) may waive the reporting obligations for this acquired entity for the first reporting cycle after acquisition. Against this background, does the framework require or allow a reclassification of the acquired entity (which used to be a Liquidation entity before acquisition with no reporting obligations) as an RLE immediately upon acquisition, implying inclusion in the group’s resolution plan and submission of the applicable reporting templates? Alternatively, may the acquired entity continue to be treated as a liquidation entity until the legal merger is completed, with its status and standalone reporting obligations remaining unchanged during the interim period? Clarification is sought on whether, in the context of M&A transactions, resolution authorities are expected to adjust the entity’s classification upon acquisition, or whether they may maintain the pre-acquisition status until legal integration is finalised.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7918
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Definition of “Substitutability” of CCPs and the connected reporting of “Alternative Providers” for the purpose of the template Z 09.04 (RESOL II).

Should the concept of substitutability of CCPs, and consequently the identification of alternative providers to be reported in template Z 09.04, be interpreted restrictively, i.e. limited to CCPs or intermediaries that are capable of providing an equivalent clearing service for the same trading venue and/or market(s)? Or should a broader interpretation of substitutability be applied, focusing on the economic function, business and regulatory objectives as well as the post-trade nature of the clearing service, under which a CCP might be substitutable not only by a concurrent CCP active on the same market, but also by: the substitution of the entire trade value chain (e.g. trading venue – CCP – CSD or trading venue – CSD); or the use of an intermediary/broker capable of rerouting either the trading and clearing activity or the transactions executed on behalf of the reporting institution through alternative FMIs, provided that such arrangements achieve a comparable economic and functional outcome for the reporting institution.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7912
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 09/10/2026

Treatment of the Right Way Risk in Call Warrant

Is a call warrant issued by the counterparty  that is also the issuer of the underlying shares exempt from counterparty credit risk requirements?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7911
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Validation Rule RRCOROF_V903610_H_C0030

Could you please clarify the validation rules newly introduced or reactivated in template C34.03 within COROFI and COROFC as of 31 March 2026? These rules require that the totals for Number of Transactions (RRCOROF_V903610_H_C0030_S0001), Nominal Amount (RRCOROF_V903610_H_C0040_S0001), Positive Market Value (RRCOROF_V903610_H_C0050_S0001 ) and Negative Market Value (RRCOROF_V903610_H_C0060_S0001)  and Add-on (RRCOROF_V903610_H_C0070_S0001) equal the sum of the respective risk categories (Interest Rate Risk, Foreign Exchange Risk, Credit Risk, Equity Risk, Commodities Risk, Other).     

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7910
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 31/08/2026

Changes between DPM 4.0 and DPM 4.2: An error has occurred while performing schema validation for the node '{http://www.eba.europa.eu/xbrl/crr/dict/met/4.2}ei86': "Other Countries" does not parse as a QName value. C_14.00 TC_14.00-L005-C0190 = Other Countries

Given that the "other countries" code was removed from  the DPM 4.2, how should these exposures be reported in COREP? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7908
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 09/10/2026

C.08.01 & C.08.02 - EBA VRs v09752_m & v09751_m

The EBA Validation Rules v09751_m and v09752_m applicable to the C.08.02 and C.08.01, respectively, state that  the column 170 (Own estimates of LGD's are used: other funded credit protection) must be equal to the sum of the  columns 171 (Cash on deposit), 172 (Life insurance policies) and 173 (Instruments held by a third party) for the following exposure classes: -  [eba_qAE:qx2022] - Total without own estimates of LGD or conversion factors- [eba_qAE:qx2020] - Central governments and central banks without own estimates of LGD or conversion factors-  [eba_qAE:qx2018] - Institutions without own estimates of LGD or conversion factors- [eba_qAE:qx2014] - Corporates - Specialised Lending without own estimates of LGD or conversion factors Should these controls be applicable?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7907
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026

Incorrect Quality Control check EGDQ_0764 for Annex I, INSTRUCTIONS FOR REPORTING ON SPECIFIC REQUIREMENTS FOR MARKET RISK, Template ({C90.00,r0010,c0080})

Data Quality ID EGDQ_0764 should be disabled as Total Assets reported in FRTB ({C90.00,r0010,c0080}) does not correspond to the amount reported in FINREP ({F01.01,r0380,c0010})

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/453 - ITS with regard to the specific reporting requirements for market risk
  • ID: 2026_7906
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Template F 13.2.1.c VariableID 433471 and 433464

Following the most recent update to the FINREP validation framework under Reporting Framework 4.2., a new data point categorization has been introduced affecting template F 13.2.1.c, specifically Variable IDs 433471 and 433464. We would appreciate confirmation as to whether this data point categorization has been correctly defined and, if so, clarification on the prudential reporting rationale underlying it. Our concern is that the validation may not be conceptually appropriate in all cases, as not all additions of foreclosed assets necessarily qualify as non-current assets held for sale.

  • 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: 2026_7904
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Exemption from deduction of Equity Holdings in an insurance company from CET1

Institution “A” currently applies the exemption provided under Article 471 CRR, whereby it does not deduct from its own funds a qualifying shareholding held in Insurance Undertaking “C” for an amount not exceeding the amount held in CET1 instruments issued by that Insurance Undertaking as of December 31, 2012 . Following the completion of a merger by absorption between Institution “A” and Institution “B” – as a result of which Institution “B”, as surviving entity, becomes the direct holder of the shareholding in Insurance Undertaking “C” by virtue of universal succession – is Institution “B” entitled to continue to apply the exemption under Article 471 CRR, as previously applied by Institution “A” in respect of such shareholding? Upon completion of the merger mentioned in question 1 above, would Institution “B” be entitled to apply the exemption under Article 471 CRR on a consolidated basis in case its direct shareholding in Insurance Undertaking “C” is transferred (as a result of a partial de-merger) to its wholly owned subsidiary Institution “D”, given that the shareholding in Insurance Undertaking “C” would in any event be held within the consolidation perimeter of Institution “B”? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7903
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 06/07/2026

Interpretation of validation rules v90316_m and v90317_m for “Average Value” column c0070 in template C 16.02

Under Regulation (EU) 2024/3117 and template C 16.02 (“Business indicator and business indicator components”), column c0070 is labelled as “Average Value”. The following validation rules apply: v90316_m:{r0310,c0070} = sum({r0320,(c0010,c0030,c0050)}) - sum({r0330,(c0010,c0030,c0050)}) / 3 v90317_m:{r0340,c0070} = sum({r0350,(c0010,c0030,c0050)}) - sum({r0360,(c0010,c0030,c0050)}) / 3 Based on standard operator precedence, the “/3” appears to apply only to the IPS adjustment terms (r0330 and r0360), and not to the complete fee and commission income/expense calculations. As a consequence, for institutions without IPS balances (r0330 = 0 and r0360 = 0), the validations effectively become: {r0310,c0070} = sum({r0320,(c0010,c0030,c0050)}) and {r0340,c0070} = sum({r0350,(c0010,c0030,c0050)}) This appears to imply that c0070 should contain a three-year cumulative sum instead of a three-year average. Could the EBA clarify whether: the current validation behaviour is intentional; or the intended validation should instead be interpreted/calculated as: (sum({r0320,(c0010,c0030,c0050)}) - sum({r0330,(c0010,c0030,c0050)})) / 3 and (sum({r0350,(c0010,c0030,c0050)}) - sum({r0360,(c0010,c0030,c0050)})) / 3

  • 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: 2026_7901
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2026

Operational risk C17 - Loss threshold calculation

For the COREP C17.01 template, in the ANNEX II INSTRUCTIONS FOR REPORTING ON OWN FUNDS AND OWN FUNDS RE-QUIREMENTS document, section 4.2. Operational Risk: Detailed information on losses in the last year (OPR DETAILS), paragraph 149 appears to clarify that banks should only report losses where the net impact over last 10 years exceeds the threshold. However, this appears to contradict with later section “4.2.2.2.     Instructions concerning specific positions”, explaining events that should have been reported previously, with gross loss over all periods exceeding threshold. We would like to ask for clarification in this case, shall we consider only impacts in the last 10 years with net loss that exceeds the threshold or consider all history for the particular event (from 2008).

  • 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: 2026_7899
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2026

IPRE and Property Collateral for Credit Risk Mitigation

When assessing the eligibility of immovable property collateral for the purposes of credit risk mitigation (CRM), how should institutions interpret the interaction between the definition of income‑producing real estate (IPRE) exposures in Article 4(75b) CRR and the conditions set out in Article 199(2) CRR for recognising immovable property as eligible collateral under the IRB approach? In particular, can immovable property collateral be recognised for CRM purposes under Article 199(2) in situations where an exposure is classified as IPRE under Article 4(75b), where repayment of the exposure is supported by diversified rental income streams across multiple properties or tenants, such that the repayment of the facility does not materially depend on the performance or cash flows of any single underlying property?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7898
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 09/10/2026

Classification of of CRR PSE under Finrep where local regulators identify them as a "non-CRR Bank"

Can a CRR PSE entity that qualifies as a Credit Institution under Article 4 of the CRR, be classified as a Credit Institution under FINREP, even if the local regulator classifies them as a "non-CRR Bank"?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7897
  • Topic: Supervisory reporting
  • Date of submission:
  • Published as Rejected Q&A: 22/09/2026

RESOL1 - how balance of cash collateral received as variation margin for intra group Repurchase Agreements should be reported in Z11.00 and Z02.00

How cash collateral received as variation margin for intragroup Repo trades be reported in Z11.00 and Z02.00 when the underlying Repo has already matured? What should be the insolvency ranking (c0030) of this balance intragroup variation margin in Z11.00?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7895
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 18/09/2026

Review EBA VR Taxonomy v4.2, Validation rule v0694_m; v0693_m; v0691_m; v0692_m; v0689_m; ; v0695_m

Could you please re‑verify the dimensions used in the following EBA Validation Rules (taxonomy 4.2), as potential inconsistencies have been identified? v0694_m v0693_m v0691_m v0692_m v0689_m v0695_m

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7894
  • Topic: Leverage ratio
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2026

Requirement for a consolidated ICARA process under Directive (EU) 2019/2034

Does Directive (EU) 2019/2034 require investment firms that are subject to prudential consolidation under Article 7 IFR to prepare, maintain and document an ICARA process on a consolidated basis? In particular, does Article 25(4) IFD impose an obligation to perform the ICARA at consolidated level, or does it merely extend the application of Part Three without creating a standalone consolidated‑ICARA requirement?

  • Legal act: Directive (EU) 2019/2034 (IFD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7891
  • Topic: Supervision of investment firm groups
  • Date of submission:
  • Published as Rejected Q&A: 15/06/2026

Relevant Services templates (Z08) Unique service title as per bank taxonomy

Can EBA confirm that using a process taxonomy that closely mirrors the nature of a servicing taxonomy complies with the requirements set for the field ‘Unique service title as per bank taxonomy'?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7890
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2026

v903250 incorrectly applied on exposure weighted averages

v903250_h is applied on (amongst others) column c0250 of C08.01, which relates to 'exposure-weighted average maturity value (days)'. The validation prescribes that r0010 should be larger or equal to rows 0015 and 0016. As in column c0250 a value-weighted average maturity is presented, it is not necessarily the case that r0010 exceeds r0015 and r0016. Therefore we feel this validation is incorrectly applied on c0250. with{tC_08.01.a, (c0020, c0030, c0040, c0050, c0060, c0070, c0080, c0090, c0101, c0102, c0103, c0104, c0105, c0106, c0107, c0110, c0140, c0150, c0160, c0170, c0171, c0172, c0173, c0180, c0190, c0200, c0210, c0250, c0255, c0256, c0257, c0260, c0270, c0280, c0290, c0300), default: 0, interval: true}: abs({r0010}) >= abs({r0015}) + abs({r0016})      

  • 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: 2026_7889
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026