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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.

List of Q&A's

Validation rules taxonomy V4.0 C_10.00

The formulae of the control v23053_m seems irrelevant

  • 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

Validation rules taxonomy V4.0 C_10.00

The formulae of the control v23052_m seems incoherent

  • 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

Validation rules taxonomy V4.0 C_08.01.a,C_08.02,C_09.02

The EBA Validation rules taxonomy v7551_m seems not relevant.

  • 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

Validation rules taxonomy V4.0 C_08.01.a,C_08.02,C_09.02

The EBA Validation rules taxonomy v7549_m seems not relevant.

  • 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

Validation rules taxonomy V4.0 C08.01/C08.02

The EBA Validation rules taxonomy v10667_m seems not relevant.

  • 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

Validation rules taxonomy V4.0 C08.01/C08.02

The EBA Validation rules taxonomy v10666_m seems not relevant.

  • 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

Validation rules taxonomy V4.0 C08.01/C08.02

The EBA Validation rules taxonomy v10664_h seems not relevant.

  • 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

Interpretation of the treatment of covered bonds under the large exposures' regime in accordance with Article 395 of the CRR and the possibility of exposure reduction pursuant to Article 399 of the CRR.

Can covered bonds used as collateral in repo transactions, which are issued by the borrower (self-issued covered bonds), be considered eligible for exposure reduction under the large exposures regime in accordance with Article 399 of the CRR, taking into account the current interpretation of Article 207(2) of the CRR and Article 400(2) of the CRR, as well as the application of ECB Regulation (EU) 2016/445?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

DPM 4.0 - Correctness of identical cells for C 08.01.c

For DPM 4.0 the cells {C_08.01.c, r0070, c0130, s*} and {C_08.01.c, r0180, c0130, s*} are identified as identical and have the same VariableID. Considering the instructions for reporting the data in rows 0070 and 0180 different values are expected.

  • 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

Taxonomy 4.0: The validation rules v7538_m and v7546_m perform consistent cross-checks?

In terms of Implementing Technical Standards (ITS), when checking the rules of the COREP_OF module for Tables C_08.01.a, C_08.02, C_09.02 have been detected inconsistencies in the validation rules under template C09.02 cross check part. It’s possible to verify this?

  • 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

Calculation of the standardised total risk exposure amount or S-TREA under Article 92(25)

Does the calculation of standardised total risk exposure amount, or S-TREA, require Firms to recalculate RWAs for standardised approaches where modelled inputs have been used? Specifically, do CVA RWAs calculated using IMM modelled EADs need to be re-calculated using EADs that have not been derived using a modelled approach?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

BTAR voluntary disclose and DPM templates

Regarding the generation of DPM templates containing ESG pillar 3 disclosure, included in reporting framework 3.3 for the ad-hoc collection, according to Commission Implementing Regulation (EU) 2022/2453, template 9 – Mitigating actions: BTAR- was required for December 24 submission only on a voluntary basis.  In case a bank has decided not to publish BTAR template in the Pillar 3 disclosure for December 2024, our understanding is that there is no obligation to deliver, for December 2024, these templates (D 09.01, D 09.02.a, D 09.02.b, D 09.02.c, D 09.02.d, D 09.03.a, D 09.03.b) included in reporting framework 3.3 to keep both reports aligned (Pillar 3 disclosure, made public in February 2025, and the reporting framework 3.3 templates). Please confirm that our view on this subject is correct.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Risk weighting attributed to gold in the form of a commodity

Is the definition of 'gold bullion', as recently amended by Regulation (EU) 2024/1623, consistent with the previous definition of 'gold' under Regulation (EU) No 575/2013 (CRR), as clarified by EBA Q&A 2016_3011, in the sense that it includes all forms of gold commodities (such as bars, ingots, jewels, manufactured products, and coins) whose value is determined exclusively by gold content—defined by purity and mass—regardless of their form, provided that no numismatic, artistic, branding, or other extrinsic value is attributed?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Clarification on Risk Weight Assignment for ADC Exposures in Default

Could you please clarify what risk weight should be applied to ADC exposures that are in default?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Reporting framework 4.0 Validation rules

Could you please confirm whether validation rule v23722_m is incorrect and should be amended, as it only counts time buckets greater than 7 years, which appears inconsistent with the ITS requirements?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Reporting framework 4.0 Validation rules release (new format) (Uploaded on 19/12/2024)

Could you please confirm whether validation rule e4900_n is incorrect and should be amended by removing r0190 from the rule and validation rule v0313_m is incorrect and should be amended by adding r0210 to the rule?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Definition of ICT service

If a supplier must provide an ICT Service to fall under DORA, how should we determine what qualifies? Should we rely on the DORA regulation’s definition of an ICT Service, or should we use the Annex 3 list (S01-S19) from the ITS Register of Information?

  • 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

Dora agreements - ICT service supports a CIF

When an ICT Service supports a Critical and Important Function (CIF) within a financial entity, providers must sign DORA agreements with their suppliers if the supplier: a)     Provides an ICT Service (as per the DORA definition). b)     Critically underpins the ICT Service, meaning its disruption could affect security or continuity (based on ITS on Register of Information, Article 3(2)(b)). Is this interpretation correct? Or must DORA agreements be signed with all critical suppliers, even those that do not provide ICT Services?

  • 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

Register of ICT Services

Are these listed listed types of ICT-services (e.g., S07, S11, S12) covered under DORA’s definition of ICT Services? If not, can, e.g., facilities or infrastructure that do not include data or digital elements be excluded from this definition?

  • 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

Definition of landline services

What are landline services in this context? Could it include fiber optics (e.g., black fiber)?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable