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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

FINREP Template F 25.01

Where should changes in a time bucket of already acquired repossessed assets be presented?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2020_5575
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

Application of Required Stable Funding on the basis of Guarantees Received

Where a loan is made to a non-financial corporate, and the loan is guaranteed by a financial counterparty such that the credit exposure on the loan is viewed by the firm as an exposure to the guarantor (financial counterparty), can the 10% RSF applicable under CRR Article 428v be applied to such a transaction?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5574
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Information to be provided by the PISP to the payer prior to the initiation of the transaction

Is it sufficient that the merchant makes available upon request by the payer (consumer) the information about the Payment Initiation Service Provider (PISP) in the Point of Interaction (POI) environment before the consumer presents their data (e.g., via a QR code) to meet the requirements of Articles 44 and 45, (2), PSD2?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5573
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 03/12/2021

Consumer explicit consent to the PISP for processing of personal data

Can the presentation by the consumer of its identification data to the merchant (e.g. CustomerID and IBAN through a QR code read by the Point of Interaction (POI)) be interpreted as the consumer providing explicit consent via the merchant to the usage of this data by a Payment Initiation Service Provider (PISP) that has a contractual relationship with the merchant (but not with the consumer) for the processing of data that will enable the initiation of a single (instant) credit transfer with the consumer’s Account Servicing Payment Service Provider (ASPSP), subject to sufficient information about this PISP made available beforehand to the consumer (in accordance with Articles 44 and 45 of PSD2)? Or is the explicit consent of the consumer to the PISP required by way of contract, as mentioned in section 3.2.1 of the EDPB Guidelines 06/2020 on the interplay of Directive 2015/2366/EU (PSD2) and the GDPR?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5570
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 03/12/2021

Interplay between Article 13a of Commission Delegated Regulation (EU) No 241/2014 as regards the deduction of software assets from Common Equity Tier 1 (CET1) items and Article 37(a) of Regulation (EU) No 575/2013 (CRR)

Would it be possible that the application of Article 37(a) of the CRR in conjunction with the new deduction rules established in Article 13a of the Commission Delegated Regulation (EU) No 241/2014 could lead to: • A negative deduction, i.e. an addition, of software assets when it comes to the determination of CET1 items, and/or • A non-adequate amount to be risk weighted?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5567
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 26/02/2021

Topping-up e-money accounts with voucher-based products

If an e-money institution (EMI) sells, through an external network of points of sale, pre-paid non-reloadable vouchers of a fixed value that can only be used to top-up e-money accounts opened with such EMIs, shall the sale of such vouchers be considered as distribution of e-money for the purposes of Directive 2009/11/EC (EMD2)?

  • Legal act: Directive 2009/110/EC (EMD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5566
  • Topic: Not applicable
  • Date of submission:
  • Published as final Q&A: 18/03/2022

Scope of internal hedges

Should transactions between non-trading books and trading books closed through clearing houses as market transactions be treated as external market transactions and therefore should they not be subject to the requirements established in Article 106 CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5554
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 04/11/2022

Unterstützungsfaktor für Infrastrukturprojekte - Supporting factor for infrastructure projects

Darf ein Institut den KMU-Unterstützungsfaktor und gleichzeitig den Unterstützungsfaktor für Infrastrukturprojekte anwenden? Is an institution allowed to apply the supporting factor for SMEs and the supporting factor for infrastructure projects simultaneously?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5551
  • Topic: Credit risk
  • Date of submission:

Treatment of cash on Nostro accounts – i.e., Bank’s cash held by a third party institution acting as a service provider for payment and settlement purposes

Do exposures related to cash on Nostro / correspondent bank accounts (i.e., Bank’s cash held by a third party institution acting as a service provider for payment and settlement purposes) qualify for a 0% risk weight (equivalent to cash and cash balances at central banks) in both Standardized and IRB approach according to articles 134(3) and 156 (a), respectively?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5550
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/11/2022

Missing reporting of Securitization under the Internal Assessment Approach in C14.01 template

Based on ITS instructions, in template C14.01 shall be reported only securitization under the SEC_IRBA, SEC_ERBA, SEC_SA methodology or securitizations weighted according to a RW equal to 1.250%. Is it confirmed that such perimeter doesn’t consider securitizations under the IAA approach, nevertheless such amount is included in CoRep template C13.01?

  • 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: 2020_5549
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

Excess collateral held by credit institution that can be contractually called at any times by the counterparty

Do we need to consider all future derivatives inflows or only the future derivatives inflows within the 30-day LCR bucket for the calculation of excess collateral?

  • 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: 2020_5544
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Bill-payment via postal service

Does bill-payment via snail-mail (postal service) fall into the definition of Article 97 1(c) and thus are subject to strong customer authentication (SCA) requirements?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5534
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 06/01/2023

Weighted Average Life calculation for Credit Card Receivables without fixed repayment scheme

Can you provide guidance on how to determine the weighted average life and the residual maturity, of credit card exposures where instalments can vary every month from a minimal amount, mainly covering interest, to the full outstanding balance, fully depending on the preferences of the obligor?

  • Legal act: Regulation (EU) No 2017/2402 (SecReg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2018/08 - Guidelines on the STS criteria for ABCP securitisation
  • ID: 2020_5532
  • Topic: Simple Transparent and Standardised securitisation
  • Date of submission:
  • Published as final Q&A: 15/07/2022

Is it correct that, in sheet Z 10.02, the Critical Function ID is not considered as a Key Value?

If the Critical Function ID is not considered as a Key Value, how can we represent the case in which we have a single critical service ID (and a single System identification code) on which there are multiple critical functions impacted?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans
  • ID: 2020_5529
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/03/2023

Soglia di materialità - Calendar Provisioning - Matheriality threshold - Calendar provisioning

In merito al tema del “Calendar Provisioning” la soglia del 20% stabilita dall’Articolo 47a(3) del Regolamento (EU) No 575/2013 come modificato dal Regolamento 2019/630, sostituisce la soglia di contagio per singolo debitore del 5% attualmente in vigore (e che il 1° gennaio 2021 diventerà dell’1%, vedi Regolamento Delegato (UE) 2018/171)? O si riferisce invece ad altri aspetti? With regard to the subject of ‘calendar provisioning’ is the 20% threshold set in Article 47a(3) of Regulation (EU) No 575/2013 as amended by Regulation (EU) 2019/630 to be considered to replace the contagion threshold for individual debtors of 5% currently in force (and which will become 1% on 1 January 2021 – see Delegated Regulation (EU) 2018/171)? Or does it refer to other aspects?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/171 - RTS on the materiality threshold for credit obligations past due
  • ID: 2020_5528
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 30/07/2021

Control of high-quality liquid assets

Does Article 8(3) LCR DR allow for a setup where certain liquidity management services such as the monetisation of high-quality liquid assets are outsourced to an external party, i.e., outside the reporting credit institution?

  • 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: 2020_5523
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 26/07/2022

Treatment of third country covered bonds under IRB Approach

Which LGD should be applied for third country covered bonds (issued under a dedicated legal framework) which are not eligible for the same LGD as UCITS 52(4)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5522
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 17/12/2021

LCR treatment of maturing securities issued by the reporting credit institution

What is the LCR treatment of maturing securities issued by the reporting credit institution where these securities are treated as deposits for the purpose of accounting?

  • 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: 2020_5518
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Calculation of specific risk own funds requirement for hedges by credit derivatives under Article 346 (4) CRR

Would be applicable the 80% offset stated in article 346(4) for the calculation of the specific risk own funds requirement of a hedged bond by an standardised credit derivative traded in a recognised exchange in case the maturity of the credit derivative is equal or higher to the bond maturity due to the standarization of the derivative.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5517
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 31/05/2022

Perform SCA by reusing an element used in an authentication exempted from SCA

When an element is used to access the payment account online, in the case the Payment Service Provider (PSP) is allowed not to apply Strong Customer Authentication (SCA) (only applying a single-factor authentication : login + password), is it possible to reuse this element to perform SCA to authenticate a transaction ?

  • 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: 2020_5516
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 15/01/2021