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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

Semi-annual reporting on the total amount of exposures to infrastructure project entities acc. to Art 501a (3)

Is the reporting on exposures to infrastructure project entities acc. to Art. 501a (3) covered by the existing CoRep forms? If not, in which form, granularity and ways institutions should report on the semi-annual basis on those exposures? 

  • 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
  • ID: 2023_6846
  • Topic: Supervisory reporting - Other
  • Date of submission:
  • Published as Rejected Q&A: 22/12/2023

Template 3 / Maturity of alignment targets

Template 3 requires information that is different from what banks have committed to disclose under their voluntary net zero commitments (for EU banks which are NZBA signatories): sectors are different, banks can use other benchmark net zero scenarios than the IEA NZE2050 and targets are due every 5 years under NZBA (vs. 3 years rolling at every reporting period in the ITS). Are new shorter-term targets expected to be set within the 5-year target period, or can banks report what they have indeed committed to through NZBA?

  • 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: 2023_6844
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 22/12/2023

Template 3 / Level of NACE codes to use

In Template 3, different levels of NACE code are indicated (level 1, 2, 3 or 4). What does this mean in practice, should banks report their full exposures falling under each level, or should exposures be reported in one category only? For example, for the fossil fuel sector a level-one NACE code is indicated (NACE code “6”) along with level 2 and 3 NACE codes (NACE code 61, 610…) – should exposures reported under code 610 also be included in exposures reported under 61 and 6? Please note that some NACE codes are overlapping (e.g. NACE code 8 is proposed for fossil fuel combustion and NACE code 89 is proposed for cement) – should exposures reported under 89 also be included in exposures reported under 8?

  • 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: 2023_6843
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 15/12/2023

Template 3 / Exposures to companies operating in several sectors

In Template 3, should corporate exposures corresponding to general-purpose financing lines be split across different sectors according to “the counterparties’ activity distribution, including by counterparties’ turnover by activity” (and therefore several different NACE codes), or should corporate exposures be fully allocated to one NACE code only corresponding to its main activity (as in template 1)? In the first option, how granular is the activity distribution expected to be reported, is there a minimum threshold of turnover to start reporting an activity? How is the information expected to be collected if not communicated by the corporates, can external data providers be used?

  • 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: 2023_6842
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 15/12/2023

Disclosure requirements for non-complex and non-listed institutions

We would appreciate clarification regarding disclosure requirements by institutions detailed in Part 8 of CRR 575/2013, more precisely Article 433b, paragraphs (1) and (2).Should non-listed small and non-complex institutions disclose paragraphs 1, points (a) and (b) on an annual basis or what should they consider to be correct, key metrics from article 447 also on an annual basis?

  • 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: 2023_6841
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 27/03/2024

CVA treatment of exposures arising from centrally cleared transactions - indirect clearing flows

Does an institution which is a client of a clearing member or a lower-level client in a multi-level client structure (institution > intermediary/higher-level client > clearing member > central counterparty) need to verify that Art. 305 (2) or (3) conditions are met at every level of the structure to exclude the transaction from the own funds requirements for CVA risk in accordance with Art. 382 (3) CRR? Guidance is sought on 4 possible clearing flows: Indirect clearing flows (clients’ transactions and institution’s own transactions) Client > institution > clearing member > CCP Institution > clearing member > CCP Multi-level indirect clearing flows (clients’ transactions and institution’s own transactions) Client > institution > intermediary/higher-level client > clearing member > CCP Institution > intermediary/higher-level client > clearing member > CCP Moreover, would the determination around the exemption from the CVA risk charge change under a scenario where the clearing member (indirect clearing flow) or the intermediary/higher-level client (multi-level client clearing flow) are intragroup entities established in a third country which has not been deemed equivalent under Article 13(2) of Regulation (EU) No 648/2012? This question has been submitted jointly with Q&A 2023_6839

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6840
  • Topic: Market risk
  • Date of submission:

CCR treatment of exposures arising from centrally cleared transactions - indirect clearing flows

Does an institution which is a client of a clearing member or a lower-level client in a multi-level client structure (institution > intermediary/higher-level client > clearing member > central counterparty) need to verify that Art. 305 (2) or (3) conditions are met at every level of the structure to apply Art. 306 (1) CRR, which might also entail zeroing out the exposure value arising from the transaction between the institution and the clearing member or the higher-level client if the institution is acting as a financial intermediary between a client and a CCP? Guidance is sought on 4 possible clearing flows: Indirect clearing flows (clients’ transactions and institution’s own transactions) Client > institution > clearing member > CCP Institution > clearing member > CCP Multi-level indirect clearing flows (clients’ transactions and institution’s own transactions) Client > institution > intermediary/higher-level client > clearing member > CCP Institution > intermediary/higher-level client > clearing member > CCP

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6839
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 02/02/2024

Template C.14 - Validation rule v11873_m - {C 14.00, c0230} + {C 14.00, c0240} + {C 14.00, c0250} <= {C 14.00, c0140}

Applicability of validation rule v11873_m introduced with DPM 3.2 in force starting from June 2023, which at the moment does not allow the reporting of values under column c140 – TOTAL AMOUNT OF SECURITISED EXPOSURES lower than the sum of columns c230 (SENIOR), c240 (MEZZANINE) and c250 (JUNIOR) positions of Template C.14.00.

  • 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
  • ID: 2023_6838
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 15/03/2024

Template C.14 - Validation rules v11662_m - if (({C 14.00, c0110} != {[eba_RS:x1], [eba_RS:x6]}) and ({C 14.00, c0230} > 0)) then ({C 14.00, c0231} != empty and {C 14.00, c0231} != 1) and v11663_m if (({C 14.00, c0110} != {[eba_RS:x1], [eba_RS:x6]}) and ({C 14.00, c0250} > 0)) then ({C 14.00, c0251} != empty and {C 14.00, c0251} != 0)

Range of applicability of validation rules v11662_m and v11663_m introduced with DPM 3.2 in force starting from June 2023.

  • 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
  • ID: 2023_6837
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 15/03/2024

In the CSRBB framework, the use of a different scope for NII and EVE

In the CSRBB framework, we want to know if banks are allowed use a&nbsp;different scope for NII and EVE.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6836
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 16/08/2023

Large exposures and guarantee received

Article&nbsp;400(1)(d) CRR states, among the exemptions from the application of paragraph&nbsp;1 of Article&nbsp;395, ‘other exposures (…) guaranteed by central governments (…) where unsecured claims on the entity (…) providing the guarantee would be assigned a 0% risk weight under Part&nbsp;Three, Title&nbsp;II, Chapter&nbsp;2’. I would like to know whether receiving 0% solvency-weighted securities issued by central governments as collateral makes us fall within the scope of this Article.&nbsp; In other words, does the fact of receiving such securities as collateral mean that the exposure in question is ‘guaranteed’ by the central government in question under this Article? If so, what are the operational conditions to be met, in particular as regards the maturity of the security vs the maturity of the exposure and as regards any difference in currency between the exposure and the security received as collateral? &nbsp; L'article 400 1-d du CRR indique, parmi les exemptions à l'application du paragraphe 1 de l'article 395,&nbsp;'les autres expositions (...) garanties des administrations centrales (...) dès lors qu'une créance non garantie sur l'entité (...) par laquelle elle est garantie recevrait une pondération de risque de 0% en vertu de la troisième partie, titre II, chapitre 2'. Je souhaite savoir si le fait de recevoir en garantie des titres émis par des administrations centrales pondérées à 0% en solvabilité nous fait entrer dans le cadre de cet article.&nbsp; Autrement dit, le fait de recevoir de tels titres en garantie fail-il que l'exposition en question est 'garantie' par l'administration centrale en question dans le cadre de cet article? Si oui, quelles sont les conditions opérationnelles à respecter, en particulier quant à l'échéance du titre vs l'échéance de l'exposition et quant à une éventuelle différence de devise entre l'exposition et le titre reçu en garantie?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6835
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 16/08/2023

Q&A 2022_6520 F 46 EBA_v1226

Where to recognise foreign exchange differences for 0010 (Capital) and c0020 (Share Premium)?

  • 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
  • ID: 2023_6834
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 02/02/2024

The SCA-Exemption for account access based on art. 10 of Regulation (EU) 2018/389 as amended by Regulation (EU) 2022/2360.

We require a clarification with reference to the art. 10 of Regulation (EU) 2018/389 as amended by Regulation (EU) 2022/2360, regarding the meaning of the sentence: “…provided that access is limited to one of the following items online…”.&nbsp; Does it mean that the 180days exemption is not allowed in case the PSU requires at the same time and in the same request: i) balance and ii) transactions-list of her/his payment account?

  • 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: 2023_6833
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as Rejected Q&A: 13/02/2024

Value of domestic payment transactions

Should the value of domestic payments transactions between credit institutions and central banks be considered for this indicator?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2019/348 - RTS on simplified obligations for recovery and resolution planning
  • ID: 2023_6832
  • Topic: Simplified obligations
  • Date of submission:
  • Published as Rejected Q&A: 26/07/2023

Deferred tax assets related tax loss due to losses on derivatives in cash flow hedge accounting relationships

In accordance with&nbsp;Article 33(1)(a) CRR, institutions do not include fair value reserves related to gains or losses on cash flow hedges in own funds. Is it correct to also filter deferred tax assets related to the tax loss resulted from fair value reserves related to gains or losses on cash flow hedges?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6831
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 16/08/2023

Clarification on EBA provisions for treatment of Non-Stable and Non-Core NMDs in SOT on NII.

Can banks, in their internal measurement methodologies for calculating the NII SOT baseline scenario, for renewed Non-Stable/Non-Core NMDs assume repricing at the current market interest rate without any commercial margin, in order to avoid stabilisation of NII on unstable funds? Is this approach in line with EBA/GL/2022/14 and permitted under EBA/RTS/2022/10?

  • 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: 2023_6830
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 15/02/2024

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  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2023_6829
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 20/07/2023

Definition of ‘turnover’ for the purposes of Country-by-Country reporting

What should be considered as ‘turnover’ for the purposes of country-by-country reporting in Article 89(1) of Directive 2013/36/EU (CRD) in light of amended Accounting directive?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6828
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 15/03/2024

Trusted Beneficiaries

Please clarify whether under Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication (hereinafter: RTS on SCA &amp; CSC) is it allowed to use the same SCA element to authorize a payment and at the same time (using the same session ID) approve&nbsp;(technically using by a checkbox) the payee as a trusted beneficiary? If it is allowed, the payment service user (hereinafter: PSU) shall be informed (prior to authorisation) by an approval SCA element (SMS) about the payment execution and about modifying the list of the trusted beneficiaries as well?

  • 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: 2023_6827
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 29/09/2023

Exposure excluded from total exposure measure for the calculation of the leverage ratio

Can the assets that represent funds deposited by a payment institution with the institution, for the fulfilment of its safeguarding obligation under directive 2015/2366 on payment services, be assigned with a risk weight of 0% to the extent they are placed by the institution with a central bank and consequently be excluded from the total exposure measure in accordance with article 429a (1) (c)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6826
  • Topic: Leverage ratio
  • Date of submission:
  • Published as Rejected Q&A: 16/08/2023