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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

Traitement des REPOs assortis d'une option "d'early termination" glissante dans le C70.00 - Handling of REPOs with a rolling ‘early termination’ option in C70.00

Comment matérialiser les REPO EVERGREEN & OPEN REPO dans le C70.00 ?How can EVERGREEN REPOs & OPEN REPOs be reported in the C70.00 template?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2019_4574
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 17/07/2020

Immediate Refund by the Payment Service Provider of unauthorised SEPA Direct Debit transactions after 8 weeks.

Our question is related to ‘unauthorised’ transactions, and as from when it is qualified as unauthorised? Is this as soon as any payment service user claims that the transaction is unauthorised?   -Or is this as soon as the payment service provider analysed if the transaction is really unauthorised?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4573
  • Topic: Other topics
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Market Risk Swap as credit derivative (i.e. Total Return Swap) applied for reducing market risk capital requirements

Can the financial contract described below (“Market Risk Swap”, MRS) be regarded a credit derivative (i.e. Total Return Swap, TRS) and be applied for reducing market risk capital requirements?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4572
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Eligibility Criteria for Tier 2 Capital in light of the replacement of LIBOR/EURIBOR

1. If the replacement reference rate proposed in the context of a change to a different benchmark rate, such as in the context of LIBOR transition, could result in a greater credit spread on an own funds instrument, whether as a consequence of a one-off adjustment to the credit spread at the time the replacement reference rate is implemented or as a consequence of an agreement to reset the credit spread at any future date or dates (whether or not in the context of any call option dates), would this potential outcome be considered to be a feature that provides an incentive to redeem for the purposes of Article 63(h) CRR? 2. If the replacement interest rate proposed by an issuer for its LIBOR-linked floating rate Tier 2 own funds instruments is a rate which is based on the credit standing of the issuer or its parent undertaking (or any intermediate parent undertaking), for example through the credit spread incorporated within a coupon derived from an overnight, or averaged overnight, risk-free rate, would that replacement rate of interest result in those instruments failing to satisfy the criterion specified in Article 63(m) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4568
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Exemptions from Strong Customer Authentication (SCA): credit transfers

Can the exemption under Article 15 of the RTS on SCA be applied to credit transfers between a personal account and a business account held by the same person.

  • 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_4564
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 19/06/2020

Reporting of contributions to the default fund of a CCP

There seems to be an incoherence between Q&A 2013_209 and the instructions contained in Annex 2 of EBA Implementing Regulation (EU) No 680/2014 regarding the Reporting of contributions to the default fund of a CCP.

  • 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_4563
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 08/05/2020

SCA profiles and multiple-use of devices

Can multiple users use the same device (i.e. smartphone) and have different strong customer authentication (SCA) profiles on the same device?

  • 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_4560
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 25/09/2020

Speculative immovable property financing definition with respect to debt-for-asset swaps

In the case described below, in individual level of reporting, should exposures to the SPVs be treated as "Speculative Immovable Property Financing" and be risk weighted at 150% under Article 128 of the CRR, or should they be RW at 100% which reflects the RW of the property included in the Consolidated level of reporting (intercompany balances are eliminated and the asset remaining in the consolidated balance sheet is the property held for sale)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4559
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Definition of payee for dynamic linking

Article 5 of the RTS on strong customer authentication and secure communication requires the authentication code to be specific to the amount of the payment transaction and the payee.Does it suffice to include a meaningful part of the identifier into the calculation of the authentication code? For instance, would it suffice to include only numeric characters of the IBAN in the calculation of the authentication code?

  • 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_4556
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 20/12/2019

COREP V2.8 - C32.02 - Prudent Valuation : Fall back Approach

Should the detail of fair value adjustments for the Core approach be reported in the information for the fall back approach?

  • 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_4555
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

Control v6363_m - Number of days of the prudent exit period ?

Could you confirm that this control must be deleted or that the number of days is more or equal to zero (and not ten) ?

  • 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_4553
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2022

Reporting of template C71.00 by significant currency

How is template C71.00 (concentration of counterbalancing capacity by counterparty) to be completed in the context of the reporting by significant currency (as referred to in Article 415(2) of Regulation (EU) No 575/2013 (CRR))? Specifically, are exposures in a significant currency going to rise in the ranking when being reported by significant currency (given that items denominated in a different currency will be disregarded in the separate currency reporting)?

  • 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_4550
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 06/09/2019

Classification of multilateral development banks (MDBs) for the purpose of the reporting of the Additional Liquidity Monitoring Metrics (ALMM)

For the purpose of the reporting of the ALMM, are MDBs to be considered as financial counterparties, non-financial corporate counterparties or other counterparties?

  • 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_4549
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 06/09/2019

Insurance policy on minimum monetary amount of the professional indemnity insurance of PSD2

If an e-money payment institution (for the purpose of new PSD2 services - Payment Initiation Service Provider (PISP) and Account Information Service Provider (AISP) in line with insurance industry standards signed an insurance policy with insurance company for several thousand/million euros with franchise deductible (e.g. in the amount of 25k EUR), fulfills adequate capital requirements and is being regularly monitored by the regulator (local central bank), does the above mentioned insurance policy violate guidelines rule that the insurance policy should not have any excess, deductible or any threshold that could prejudice repayments or do we understand it correctly that such insurance policy does not in any case prejudice that potential refunds requests will not be refunded and it as such fulfills guideline requirements? We understand that such insurance does not prejudice any repayments.

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/08 - Guidelines on the criteria on how to stipulate the minimum monetary amount of the professional indemnity insurance
  • ID: 2019_4542
  • Topic: Monetary amount of the professional indemnity insurance
  • Date of submission:
  • Published as final Q&A: 31/07/2020

COREP C06.01 template - Consistency of the EBA taxonomy control v6288_m

Is the control v6288_m consistent with the COREP ITS?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4537
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 12/07/2019

COREP C 14.00 template - Consistency of the EBA taxonomy control v4801_m

Is the control v4801_m consistent with the COREP ITS?

  • 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_4535
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 17/07/2020

Strong Customer Authentication (SCA) possession element requirement for cryptographic validation

For a device to be considered possession:-a) should the device perform "cryptographically underpinned validity assertions using keys or cryptographic material stored in" the device?b) should the device be in the physical possession of the  Payment Service User (PSU)? I.e. it cannot be held and operated remotely.

  • 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_4532
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 24/07/2020

Include all entities which belong to a group of connected clients in Large exposure templates

Should credit institution report all entities which belong to a group of connected clients in their C 29.00 template, including those which do not have any direct or indirect exposure with this credit institution?

  • 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: 2019_4525
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 26/11/2021

Col 040 of Corep: C 32.04 - Prudent Valuation: Concentrated Positions AVA (PRUVAL 4) report

As per article 14 (details available below), col 040 of Corep C32.04 report is quite subjective. But to the best of our interpretation can we say that its a percentage value and is computed as Col 040 = ( CONCENTRATED POSITIONS AVA (Col 080) / Total CONCENTRATED POSITIONS AVA )* 100

  • 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_4519
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 30/04/2021