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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

ESG P3 - Template 5 - NUTS codes for geographical areas outside EU

Does the regulation authorize to disclose any geographical area located outside European Union (EU) and UK?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2023_6679
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 10/03/2023

ESG P3 - Template 1- Attribution factor for financed emissions

In Template 1 of the final ITS, Commission Implementing Regulation (EU) 2022/2453 the GHG financed emissions should be reported in colimn i. With reference to the Annex 2 of the Regulation, institutions should  "taking into account their exposures [...] compared to total liabilities (accounting liabilities and shareholdes' equity)". This expression refers to an attributions factor that is similarly used in the GHG/PCAF-standard (EVIC, i.e. debt and equity). According to the expression, the attribution factor only applies for the "scope 3 emissions per sector" and is not explicitely named in column j for the "Of which Scope 3 financed emissions". Does the CRR-449a-attribution factor in column i and j apply for scope 1/2/3 of the counterparty? Does the attribution factor deviate from the GHG/PCAF-standard?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2023_6678
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 10/03/2023

ESG P3 - Template 1- Scope 3 financed emissions including scope 1 and 2 of the counterparty

In Template 1 of the final ITS (Commission Implementing Regulation (EU) 2022/2453) in column j the "Of which Scope 3 financed emissions" should be reported. Reading Annex 2 of the Regulation, "Institutions shall disclose their scope 3 emissions" where "their" refers to "institution" - this would be the scope-3-financed emissoions of the PCAF standard and therefor the total financed  emissions inclusing scope 1 /2 /3 of their (!) counterparties. Is is correct, that here only the counterparties scope-3-emissions should be reported?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2023_6677
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 10/03/2023

ESG P3 - Template 1- financed emissions to objects (PCAF-Standard) instead of counterparties

Regarding template 1 (ITS Commission Implementing Regulation (EU) 2022/2453) the "GHG financed emissions (scope 1, scope 2 and scope 3 emissions of the counterparty)" [see Annex 1] have to be reported. With respect to Annex 2 of the Regulation, the Reporting Standard of the Financial Industry (PCAF) is referenced (page 13), that is related to the institutions ("their") scope 3 emissions. Therefore, regarding projekt/object finance, we are not clear if the financed emissions of the specified object or the counterparty should be reported. E.g., if a bank finances/leases a car of/to a counterparty, should the scope 1/2/3 emissions of the counterparty (e.g. the company that buy the car that is partially financed by the bank)  be reported or the emissions of the car? So forth, should the attribution factor for the company or the attribution factor for the car (loan) be used?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2023_6676
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 10/03/2023

Consideration of own funds requirements as a comparable guarantee to the PII

Would it be acceptable to consider, has a possible comparable guarantee, an increase of own funds’ requirements, in an amount corresponding to the minimum monetary amount calculated in accordance with the EBA’s tool, while ensuring that this amount would be fulfilled with highly liquid assets?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6675
  • Topic: Monetary amount of the professional indemnity insurance
  • Date of submission:

SRT test in securitisations

When is necessary to make de SRT test in securitisations: at initial assessment only or ongoing monitoring?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6674
  • Topic: Securitisation and Covered Bonds
  • Date of submission:

NACE sector K- 'Financial and insurance activities' in F 06.01

How should the instructions from Regulation (EU) 2021/451, (ITS), Annex V, Part 2, paragraph 92 ‘Institutions shall report loans and advances to non-financial corporations which engage in financial or insurance activities in ‘K – Financial and insurance activities’’ be understood? As an example, should a counterparty whose primary activity is NACE code 7010 ‘Activities of head offices’ (sector M), who also performs the activity ‘other financial service activities, except insurance and pension funding n.e.c.’ (NACE code 6499) be presented in F 06.01 in sector K ‘Financial and insurance activities’ or in sector M ‘Professional, scientific and technical activities’?

  • 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: 2022_6673
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 28/04/2023

NACE reporting in FINREP

In FINREP where presentation towards NACE sector is requested, in case the immediate counterparty is a holding company, should the applicable NACE sector be based on the NACE sector applicable for the holding company itself, or should the NACE sector be based on the NACE sector of the specific obligor under the holding company which receives the funding from the holding company?

  • 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: 2022_6672
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 28/04/2023

Contents of C03, row 0220 (Surplus(+)/Deficit(-) of CET1 capital considering the requirements of Article 92 CRR and 104a CRD)

The instructions for this memo item in C03 in Annex 2 of the ITS on Reporting (Regulation (EU) 451/2021) would need some clarification if one of the conclusions of Q&A 2016_2552 is considered.

  • 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: 2022_6671
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 16/10/2023

The risk-weighted exposure amount of the CIU’s exposures in mandate based approach

Could the institution use the information from the CIU management company about the notional amount of derivative positions of CIU to assess the value of those derivatives in calculating risk-weighted exposure amount of CIU when using the mandate based approach in accordance with Article 132a(2) CRR? In particular, is the institution allowed to use the information from the CIU management company, that CIU doesn’t have derivatives in their portfolio and assess the value of those derivatives as zero in calculating risk-weighted exposure amount of CIU when using the mandate based approach in accordance with Article 132a(2) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6670
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 04/08/2023

Use of 2 % threshold for general credit exposure

When filling out reporting template C 09.04 in Annex I to Regulation (EU) 2021/451 (ITS on Reporting) rows 0150 and 0160, should 'n' be populated in the respective cells for all templates where 'y' is not indicated, or just for the those corresponding to the Member State and the 'Total' for all countries?

  • 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: 2022_6669
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 26/01/2023

NSFR RST accrued interest recognition

In Annex XIII, Part I, point 6 is written, that for reporting purposes, in the columns referred as “Amount” the accounting value shall always be reported, except for the cases of derivative contracts, for which institutions shall refer to the fair value as specified in Article 428d(2) CRR. Also Part II, 1.13 tells that ll non-HQLA assets and off-balance sheet items shall be reported with a breakdown by their residual maturity in accordance with Article 428q CRR. But in which time bucket do accrued interest amounts of loans fall into - < 6 months, ≥ 6 months to < 1 year or ≥ 1 year? It seems that they should be included into time bucket '< 6 months'. Read the Question ID: 2013_656, but no clear answer about accrued interest. So could you please clarify this?

  • 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: 2022_6668
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 14/09/2023

One Percent threshold to report an institution in the TOP 10

Should the institution report the section 1 of C67.00 based of 1% of total liabilities or based of 1% of total liabilities reported in section 1? In other words, based on Q&A 2018_4209 which has been published after the release of DPM 3.00 will you updated AMM ITS?

  • 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: 2022_6664
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 04/05/2023

Reporting of deposits subject to a notice period for C 69.00 and C 70.00 purpose

Following Q&A Q&A 4574 (C 70.00) and Q&A 5794, some clarifications are needed concerning the amount to be reported in the C 69.00 for a deposit subject to a notice period. In our proposed answer, we use the terms of the Q&As and we specify the amounts we assume are expected for the 2 reports C 69.00 and C 70.00. Please, could you confirm if our interpretations are correct.

  • 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: 2022_6663
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 28/07/2023

Large exposure treatment of structured derivatives, such as collar financing transactions (‘CFTs’)

For the purposes of large exposures (‘LE’), what is the appropriate treatment for structured derivatives (like covered calls, CFTs, etc.) in the application of the mandatory substitution (‘risk shifting’) rule in accordance with CRR Article 401(4) that requires an institution to treat the portion of the exposure collateralised by the market value of funded credit risk mitigation (‘CRM’) as exposure to the third party (collateral issuer) rather than to the client?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6662
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 27/01/2023

C08.01: Unclear scope for exposures to be considered in column 0310 “PRE-CREDIT DERIVATIVES RISK WEIGHTED EXPOSURE AMOUNT”.

Shall the reporting amount in template C08.01 in Annex I to Regulation (EU) 2021/451 (ITS on Reporting) in the cell r0010;c0310 include “hypothetical risk-weighted exposure amount pre-credit derivates” all exposure types or only contain the exposure types for “counterparty credit risk”-exposures as reported in rows 0040 – 0060 of the same template?

  • 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: 2022_6661
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 26/01/2023

Calculating risk-weighted exposure amounts under the standardised approach for exposures guaranteed by a Member State’s central government denominated in the domestic currency of that central government when the exposure is denominated in a different currency that is the currency of another Member State

For exposures guaranteed by a Member State’s central government where the guarantee is denominated in the domestic currency of that central government, the central government as protection provider shall be assigned a 0% risk weight if the exposure is denominated in a different currency that is the currency of another Member State?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6660
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 28/02/2023

C66 taxonomy 3.2

Le « livret jeune » doit-il être déclaré dans la colonne 025 du nouveau C66? Should the livret jeune be reported in column 025 of the new C66?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6659
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 28/09/2023

Own Funds Requirement (OFR) calculation without permission to use articles 325 and 352(2) CRR permission/exemption.

How should institutions, without both the permission referred to in article 325 of the CRR and the permission referred to in article 352(2) of CRR, compute, on a consolidated basis, the overall net foreign exchange position (“ONFEP”), according to article 352(1) of the CRR and subsequent amount of own funds’ requirements for market risk?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2020/09 - Guidelines on the treatment of structural FX under Article 352(2) of CRR
  • ID: 2022_6658
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 01/03/2023

How to fill in row 0150 on "Equity" in C 08.07

In the C08.07 report, column 0010 'TOTAL EXPOSURE VALUE AS DEFINED IN ART 166 CRR' refers to Article 166 which applies to exposures to companies, institutions, central governments and central banks and retail customers. If this column concerns the elements mentioned in Article 166, row 0150 “EQUITY” should not be filled in column 0010. Can you tell us if row 0150 “EQUITY” in column 0010 “TOTAL EXPOSURE VALUE AS DEFINED IN ART 166 CRR” must be completed?

  • 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: 2022_6657
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 03/03/2023