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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

Strong customer authentication requirement on pay-by-invoice payment transactions

Does Article 97(1)(b) PSD2 apply for pay-by-invoice when the payer's funds are covered by a credit line extended by a payment service provider?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4484
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 21/01/2022

Unattended terminals and Transaction Risk Analysis (TRA) exemption and related Payment Service Providers (PSP)’s liabilities rules

Provided that both the payer’s Payment Service Provider (PSP) and the payee’s PSP can apply the strong customer authentication (SCA) exemption, without prejudice to the last say of the payer’s PSP, can a payment made at highway toll booths be treated as the one performed at the unattended terminals for transport fares?

  • 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: 2019_4480
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 19/06/2020

Calculation of foreseeable dividend to be deducted from interim profits when interim dividend has been paid

How exactly is the amount of interim profit to be included in Common Equity Tier 1 calculated according to Article 2(2) to (4) of the Regulation (EU) 241/2014 when the interim dividend has already been paid out and yet no final divided has been formally decided or proposed to the institution’s relevant body?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4477
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 15/05/2020

2% threshold in template C.09.04

Which is the correct way to calculate the 2% threshold for general credit exposures in the context of the institution specific counter-cyclical capital buffer (CCB)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2019_4474
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 08/05/2020

Meaning of “portfolio” within “sufficiently diversified portfolios” in Article 155(2)

How should the term “portfolio” be understood in the context of the 190% risk weight for private equity exposures in “sufficiently diversified portfolios” in Article 155(2) of the CRR? Does it refer to the whole institution’s portfolio of private equity? Or to any of the “portfolios” that an institution has identified for internal risk management purposes instead?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4472
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 07/05/2021

Applicable methodology for unfunded reserves and liquidity reserves

How should the risk-weight of reserves for which the computation of D and A is not required be determined?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4466
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Application of Article 254(2) to derivative exposures

Is new Article 254(2) CRR applicable to derivatives positions to hedge market risk?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4465
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as final Q&A: 15/11/2019

Validation rule v1088_m

Validation rule v1088_m verifies that the amount entered in F01.01 row 280, column 010 (Property, Plant and Equipment in the Balance Sheet Statement) should be equal or larger than the amount entered in F13.02 row 020, column 010 (Property, Plant and Equipment obtained by taking possession during the period). This validation rule implies that collateral obtained in the form (nature) of Property, Plant and Equipment is classified in the Balance Sheet Statement as Property, Plant and Equipment. We believe in most cases the collateral obtained by taking possession will be classified as either held for sale (based on IFRS 5.6 and meeting the requirements from IFRS 5.7) or as “other assets” (based on meeting the conditions of IFRS 5.6, but not IFRS 5.7 (plan for immediate sale in present condition and sale being highly probable)) and thereby will be reported in either F01.01 row 370, column 010 or F01.01 row 360, column 010. We therefore question whether the current validation rule is appropriate.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2019_4464
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Clarification of negative RWA--, Annex III, Benchmarking exercise

What should we do if the value of RWA-- gets negative? Should we do nothing or should the value change to example 0?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2019_4459
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Offset of Additional Value Adjustments (AVA) against day one profits deferral

Under Article 8(3), is day one profit deferral eligible to offset the AVAs under Articles 9, to 17 of Regulation (EU) No. 2016 / 101?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/101 - RTS for prudent valuation under Article 105(14) CRR
  • ID: 2019_4458
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 29/11/2019

Unique row identifier for template Z 08.00 - Critical services (SERV)

According to Annex II to ITS on Reporting for Resolution Plans, the combination of values regarding Service type, Service recipient, Service provider, Critical function and Country shall define a unique row identifier.Given that the combination of values defined as row identifier in template Z 08.00 of Annex II to the ITS on Reporting for Resolution Plans may actually be common to different contracts having different contractual provisions, how, if at all, should institutions report these contracts? (i.e. do institutions have to report one row for each contract, identified by field 0005 Identifier, which would be part of the single row identifier?)

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on the provision of information for the purpose of resolution plans
  • ID: 2019_4457
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Allocations to the funds for general banking risk

Can banks allocate items to their funds for general banking risk without waiting for the annual accounts? If yes, is Art. 26 (2) CRR applicable for allocations during the financial year?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4453
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Potential inconsistency on the application of Strong Customer Authentication exemptions to AISPs

Shall Account Servicing Payment Service Providers (ASPSPs) always grant Account Information Service Provider (AISPs) to be exempted from Strong Customer Authentication (SCA) according to rules defined in Article 10 of the RTS on strong customer authentication and secure communication (Delegated Regulation (EU) 2018/389), or is the final decision to apply such exemption always up to the ASPSP?

  • 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: 2019_4450
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

IRRBB Application of the sudden parallel

How should banks apply the sudden parallel +-200 basis points shift of the yield curve in their forecast yield curve?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2015/08 - Guidelines on the management of interest rate risk arising from non-trading activities
  • ID: 2019_4448
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 15/11/2019

To which exposure class the fair value changes of the hedged items in portfolio hedge of interest rate risk should be assigned

To which exposure class the 'fair value changes of the hedged items in portfolio hedge of interest rate risk' (recorded in the IFRS consolidated financial statements in accordance with (IAS 39.89A(a); IFRS 9.6.5.8) have to be assigned. The recorded exposure relates to a bottom layer macro fair value hedge of mortgage loans. Due to the application of the bottom layer macro fair value hedge approach there is no individual allocation of the exposure value of the hedged item to the individual mortgage loans. Should this exposure be treated as an 'exposure secured by mortgages on immovable property' or as 'other items', and subsequently, which risk weight should be applied to this exposure.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4441
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Revocation / Invalidation of SCA proof before execution date

In order for a payment instruction to be regarded as 'authorised', is the Account Servicing Payment Service Provider (ASPSP) obliged to verify the strong customer authentication (SCA) proof immediately prior to the execution of each future dated payment instruction? If the ASPSP fails to re-verify the SCA proof, can the ASPSP hold the payer liable in the event of fraud?

  • 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: 2018_4440
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 17/12/2021

Fraud rate calculation for TRA exemption – country dimension

Could – or should – the fraud rate for the TRA exemption be calculated per member state where a PSP provides payment services (one legal entity with branches in different countries), or should the fraud rate be aggregated as one for the whole legal entity?

  • 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: 2018_4439
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 12/04/2019

SA or IRB treatment of CCPs for AIRB banks

Does article 306(1)(b) of the CRR imply (or not) that trade exposure and default fund contributions to non-qualifying CCPs should be considered as exposures designated to the SA even in case an IRB authorization exists?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4437
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Prudent valuation - new template C.32.01

At the analysis of the new template C.32.01 which must be filled starting from reporting date 31.12.2018 we found some constellations which we cannot allocate so easily in the new form. Here we would ask you for guidance. 1. Eurex-Netting Here derivatives of different hedging relation and valuation categories are netted and the netting result is finally shown in only one finrep position which is derivatives – hedge accounting (in the template rows 1.1.9 or 1.2.4). Here are also some derivatives included for which the hedging relation should be shown in column 030 exactly matching. The reason is that the other deal of the hedging relation which is not part of the netting agreement is also shown here. At the rows 1.1.9 or 1.2.4 the column exactly matching is, however, shown greyed out. If we – for instance – evade to column 040 other, then column exactly matching does no longer show the same total on the asset side and the liabilities side what – we suppose – would contradict to the expectations of EBA. How can we show this constellation properly in the template? 2. Portfolio Fair Value Hedge Accounting (rows 1.1.10 and 1.2.5 in the template) We regard the bookings in this balance sheet positions also as a part of hedge accounting and thus cannot understand why in these rows 1.1.10 and 1.2.5 column 040 hedge accounting is shown greyed out. Where can we show in the template the deduction items which we calculate for prudent valuation at portfolio fair value hedge accounting? 3. Change of algebraic sign at some trades There are cases where the total book value is lower than the hedge adjustment included in the book value. This means that after elimination of the hedge adjustment in column 030 or 040 the algebraic sign of the book value changes. In the result column 080 the problem is solved by showing the absolute value for the calculation basis for the prudent valuation of every deal. So undesirable netting effects inside this column are avoided. At the deduction rows 030 – 060 it is not so easily possible to show a transparent calculation. Example: Deal 1 Book value 80 Hedge Adjustment 100 Result 20 (absolute value) Deal 2 Book value 100 Hedge Adjustment 90 Result 10 (absolute value) Then the cells in template show the following figures: Book value 180 Hedge adjustment 190 Result 30 (absolute value) This is correctly calculated, but not transparent and the validation rules are not complied with.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2018_4436
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2022

Dynamic Linking for batch payments

With regards to dynamic linking for a batch of remote electronic payments, should the authentication code be linked to each and every IBAN of all the beneficiaries in a batch file?

  • 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: 2018_4435
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 20/12/2019