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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

PISP payment order cancellation due to fraud prevention reasons

Due to fraud prevention reasons, could an ASPSP block a payment order initiated through a PISP despite having informed the PISP immediately upon authentication, that the payment was going to be executed (i.e., after having provided the PISP with the code ACSC under the Berlin Group Standard)? In that scenario who should bear the liability if the payment is not executed but, nonetheless, the payee delivered the good or service promptly after being informed by the PISP of the successful initiation of the payment?  Would the answer be different if the ASPSP had simply confirmed the sufficiency of funds as stated in the EBA Opinion on the implementation of the RTS on SCA and CSC (EBA-Op-2018-04)   

  • 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_6873
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:

Data collection regarding high earners that are staff in investment firms subject to Article 25 and 34 of Directive (EU) 2019/2034 when the investment firms are part of a group subject to prudential consolidation.

Point 18 of EBA/GL/2022/08 states: “High-earners data should be submitted (…) by: a. institutions referred to in Subsection 1.1, using the template for the data collection specified under: i. Annex I for high earners that are staff of institutions and other entities in the scope of consolidation; ii. Annex II for high earners that are staff in investment firms subject to Article 25 and 34 of Directive (EU) 2019/2034;” We have found that there are several common data points defined between R 04.00 and R.04.01 (in particular columns 0010, 0020 and 0070 of R 04.01) in XBRL taxonomy version 3.2. which technically prevents the possibility to report according to point 18 of EBA/GL/2022/08. For example, supposing an institution has one member of the MB Supervisory function (column 0010) reported in “Number of other staff” (row 0030) in an investment firm (point ii) and four members of the MB Supervisory function (column 0010) reported in “Number of other staff” (row 0030) in the parent institution (point i), it cannot report one person in R 04.01 and four people in R 04.00 due to the common data points between them.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2022/08 – Guidelines on the data collection exercises regarding high earners
  • ID: 2023_6872
  • Topic: Remuneration
  • Date of submission:
  • Published as Rejected Q&A: 01/05/2024

validation rules eba_v2822_m and eba_v2823_m

In finrep we report a negative amount in the cell F01.01 R250 C0010 "fair value changes of the hedged items in portfolio hedge of intererest rate risk". According to the validation rule V2823 we have to report this cell in the F32.01 line 120 "other", but if we do so the amount reported in F32.01 line 120 is negative and the AE reporting does not accept negative amounts. Another solution (our preference) is to report it together with the loans reported in F01.01, as the negative fair value in F01.01 R250 concerns a fair value correction on credits. In this case the F32.01 line 120 is positive and accepted, but the validation rules V2823 (check of F32.01 Line 120 with Finrep) and V2822 (check of F32.01 Line 110 with Finrep) are breached.

  • 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: 2023_6871
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as Rejected Q&A: 31/01/2024

Validation rule v7364_m - Securitisation Template C 14.00

Should validation rule v7364_m take into account other eligible asset types for the underlying pool of 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_6870
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 14/02/2024

Validation rule v11873_m - Securitization Template C 14.00

Should validation rule v11873_m be amended for securitisation programs under an active replenishment period?

  • 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_6869
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 14/02/2024

Determination of the delta factor for K-TCD

Shall a delta of 1 according to Art. 29 (6) IFR be used for the calculation of the effective notional A) if no option price model has been approved at all or B) where a model for a specific instrument type has not been approved by the competent authorities, while for models of other instrument types there is an approval?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6868
  • Topic: K-factor requirements
  • Date of submission:
  • Published as Rejected Q&A: 15/01/2024

Template C 08.01 – Validation rule v10667_m - {C 08.01.a, r0070, c0250} * sum({C 08.02, c0110, (rNNN)}) = sum({C 08.02, c0250, (rNNN)} * {C 08.02, c0110, (rNNN)})

Range of applicability of validation rule v10667_m in force starting from June 2023 with DPM 3.2.

  • 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_6867
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:

Template C 14.00 - Validation rule v11661_m - ({C 14.00, c0231} >= {C 14.00, c0251}) or ({C 14.00, c0265} >= {C 14.00, c0251}) - If value missing (but table prerequisites met) “treat as zero/empty string”, Template C 13.01 – Validation rule v7430_m - {c0710} = {c0720} + {c0740} + {c0760} + {c0830} + {c0850}

Range of applicability of validation rules v11661_m and v7430_m in force starting from June 2023 with DPM 3.2.

  • 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_6866
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 26/04/2024

C14.00 - v11661_m - Attachment and Detachment points

The EBA Validation Rule v11661_m states that: For all securitization programs (on-balance or off-balance) the attachment point (AP) of the senior tranche must be higher than the detachment point (DP) of the first loss tranche. Should this control be applicable? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6865
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 14/02/2024

C14.00 - v7364_m - Type of Assets (column 0160)

The EBA Validation Rule v7364_m states that: For securitization programs qualified for differentiated capital treatment and classified as traditional (and Non NPE), synthetic or ABCP, then the asset class of the portfolio (C14.00 - c0160) must be “Loans to SME (treated as corporate)” or “Loans to SME (treated as retail). Should this control be applicable?

  • 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_6864
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 26/04/2024

Mobile Banking Services and SCA in the same app

We use a mobile app, software installed in a separate sandbox on a multi-purpose device, for the elements of strong customer authentication. Is it correct to assume that Article 9 (in COMMISSION DELEGATED REGULATION (EU) 2018/ 389) does not prevent us from offering mobile banking services through the same app?

  • 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_6863
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:

materiality of Basis Risk

"Where the sum of floating rate instruments": Does the Sum refer to the 1)Net of reprining notional of Asset/Liability of floating rate instruments; or 2) Asset only ( as the denominator is 5% of assets), or 3)absolute value of Asset plus absolute value of Liability?  

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6862
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 16/10/2023

Minority interests ( COREP & Net Stable Funding Ratio)

Are minority interests that arise from a subsidiary, which is a (Mixed) financial holding company in a third country and has obtained exemption for the prudential consolidation from the local regulator, eligible to inclusion in the EU parent entity consolidated? Can parent entity choose to apply CRR articles 84(2)/87(2) to exclude the minority interest of the subsidiary with potential negative equity ? What should be the treatment of the minority interest of the subsidiary with potential negative equity in the NSFR report of the parent entity?   

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6861
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 16/10/2023

C34.02 - reporting of VM, RC and PFE when EAD is capped for margined business under SA-CCR

Under SA-CCR, when EAD for margined business is being capped at EAD value as if unmargined business (as per CRR Article 274 (3)), should all the atributes of the netting set change in reporting as if it were unmargined business? Namely: - columns 0060 or 0070 should report no value as VM or report the VM posted/received in the margin agreement (in line with ITS)? - column 0100 should report the RC calculated as if unmargined (as per CRR Article 275 (1) formulae) or report the RC calculated based on the status of margined business (as per CRR Article 275 (2)? ; same for column 0110 for PFE - netting set should flow in row 0140, unmargined business, or in 0130, margined business (as it is contractually established)?

  • 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_6860
  • Topic: Supervisory reporting - Other
  • Date of submission:

ESG P3 - Template 3 - Indicators of potential climate change transition risk: Alignment metrics

In accordance with COMMISSION IMPLEMENTING REGULATION (EU) 2022/2453 in template 3, the institution shall disclose: 1/ Alignment metric(s) (column d) applied and the closest year of reference (column e) for the alignment metric(s) for each sector. Regarding the reference date, does it refer to the reporting date? Should it therefore have to change biannually depending on the publication of ESG Pillar 3? Otherwise, how often does it have to be updated?  2/ Institutions’ target for 3 years after the year of reference: If the reference year is different from the year of reporting (see question 1), for instance 2020 as reference date, then the target (column g) will be 2023 but as soon as the institution published the reporting for June 2024, this target won’t be relevant. Should the institution updated it and start again from 2023 as the reference date?

  • 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_6859
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 15/12/2023

Treatment of derivative positions in the event of counterparty default

Should the outflows from derivative transactions be taken into account in the calculation of the LCR ratio, when the counterparty is in default?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement
  • ID: 2023_6858
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 23/10/2023

Treatment of early repayment of the targeted longer-term refinancing operations (TLTROs)

Should a 0% outflow rate be applied to the cash outflow from the early repayment of the TLTRO facility by a bank, which will occur within 30 days?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/61 - DR with regard to liquidity coverage requirement
  • ID: 2023_6857
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 16/10/2023

Pillar 3 ESG Template 3 – NACE sectors scoping

The list of minimum NACE sectors provided in the template includes a combination of level 2, level 3 and level 4 NACE codes. Does this mean that if a NACE level 2 sector is mentioned, all the underlying NACE level 4 sectors are included? Or should only the level 4 NACE sectors explicitly mentioned in the list be included?  

  • 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_6856
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 15/01/2024

Pillar 3 ESG Template 3 – Decarbonization scenarios

Is it allowed to alternatively use reliable scenario sources other than the IEA NZE2050 scenario, which are more specific to certain sectors? Examples are the International Maritime Organization (IMO) decarbonization scenario towards 2050 for the maritime shipping sector and the CRREM 1.5C decarbonisation trajectories for commercial real estate.

  • 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_6855
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 12/01/2024

Validation rules and warnings

Due to the increase of interest rates, the 'fair value changes of the hedged items in portfolio hedge of interest rate risk' is a negative number on the asset side of the balance sheet. In the NSFR this amount is reported under 'other assets' (C80.00 R1030). However, we obtain multiple warnings eba_v11531_s, eba_v11537_s, eba_v11546_s, eba_v11552_s, eba_v11565_s, eba_v11582_s. Is it possible to report a negative number under other assets, and if not where should we report the negative amount of 'fair value changes of the hedged items in portfolio hedge of interest rate risk'

  • 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_6853
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 01/05/2024