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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

Reporting of debt securities issued but not yet paid up

What is the expected representation for a debt security issued but not yet paid up in the templates REPRICING CASH FLOWS (J05, J06 and J07)? Is the expected monetary inflow supposed to be reported and if so in which row?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)
  • ID: 2025_7610
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:

COREP Template 236. Specialised Lending Supervisory Slotting Method

How should institutions reflect, in COREP template C 08.01, credit risk mitigation (CRM) techniques applied to exposures subject to the slotting approach?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions
  • ID: 2025_7596
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

ASF factors for Additional Tier 1 items as wells as Tier 2 items and other capital instruments maturing between 6 month and 1 year

For the purpose of calculating the NSFR, which appropriate available stable funding factor shall institutions apply for Additional Tier 1 items as well as Tier 2 items and other capital instruments maturing between 6 month and 1 year?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)
  • ID: 2021_6017
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 07/10/2025

Customers short sales internally matched with other clients’ long positions, as part of primary brokerage services

What is the expected treatment in the Liquidity Coverage Ratio of an internalized transaction, maturing within 30 calendar days, where the institution grants a margin loan to a client against a collateral that does not qualify as liquid assets and where this collateral is lent to another client to cover short sales?

  • 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: 2025_7595
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 10/11/2025

FINREP – Loan commitments, financial guarantees and other commitments given

In the context of FINREP template F 09.01, could the EBA clarify whether the scope of columns 0100 and 0110 is intended to include exposures (commitments and certain contractual arrangements that are not commitments as referred to in CRR Article 5/110a/111(4)) that fall under CRR3 Annex I but are not recognised or disclosed under IFRS 9, IFRS 7 or IAS 37?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2025_7592
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Investment of funds received in exchange of e-money tokens

Do banks (credit institution) need to maintain segregated account to safeguard the proceeds from e-money token issuance?

  • Legal act: Regulation (EU) No 2023/1114 (MiCAR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7591
  • Topic: Other MiCAR topics
  • Date of submission:
  • Published as Rejected Q&A: 11/11/2025

Access to national credit databases for all EU creditors for both cross-border and domestic mortgage loan transactions

Considering that Article 19 of Directive (EU) 2023/2225, repealing Directive 2008/48/EC (the ‘Consumer Credit Directive 2’), grants creditors from a Member State other than the one where a credit database is located access to that database only in relation to cross-border credit transactions, does the reference to the framework of Directive 2008/48/EC in Recital 20 of Directive 2014/17/EU (the ‘Mortgage Credit Directive’) imply that Article 21 MCD likewise provides creditors with access to databases solely for cross-border credit transactions?

  • Legal act: Directive 2014/17/EU (MCD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7588
  • Topic: Creditworthiness assessments
  • Date of submission:

Deduction of pledged own shares from Common Equity Tier 1 items

Institutions, in the context of private banking and or corporate banking business, provide liquidity to investor/clients for purposes of their own commercial business (unrelated to the acquisition of the institution’s own shares). This is carried out by providing loans pledged with financial collateral in the form of equity shares, corporate bonds, sovereign debt, term deposits or cash in a sight account. Under the contractual arrangements of the loan and the pledge, as well as applicable legal regulation in our jurisdiction, in the event of default of the obligor the institution is not allowed to foreclose the financial collateral. Instead, it is allowed to sell the collateral in the market and seize the proceeds. However, the institution is only allowed to sell collateral in the amount that is required settle the debt of the obligor, no more. Financial collateral is valued daily and therefore the institution can sell it in the market until the debt is settled in full. Accordingly, the amount of the synthetic holding should be the accounting value of the pledged shares limited by the limit of the EAD of the loan. We present below two scenarios where there is overcollateralization. Scenario 1 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of the institution’s own equity shares in the amount of 150 shares that are valued in the market 1 monetary unit each, for a total amount of 150 monetary units.  The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares to settle the debt and therefore the deduction should be the accounting value of 100 shares as per Q&A 2020_5128. Is the approach followed by the institution, correct? Scenario 2 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of: 100 shares of the institution own shares that are valued in the market 1 monetary unit each, for a total amount of 100 monetary units. 100 shares of another company, for the purpose of the scenario is an industrial company, that are valued at 1 monetary unit each, amounting a total of 100 monetary units. The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares in total and would sell in the market the obligor’s portfolio prorate, i.e. 50 shares of the institution and 50 shares of the shares of the industrial corporate. Accordingly, the deduction would be the accounting value of 50 shares of the institution, in line with Q&A 2020_5128. Is the approach followed by the institution, correct?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7586
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/11/2025

Deduction of pledged own shares from Common Equity Tier 1 items

Institutions, in the context of private banking and or corporate banking business, provide liquidity to investor/clients for purposes of their own commercial business (unrelated to the acquisition of the institution’s own shares). This is carried out by providing loans pledged with financial collateral in the form of equity shares, corporate bonds, sovereign debt, term deposits or cash in a sight account. Under the contractual arrangements of the loan and the pledge, as well as applicable legal regulation in our jurisdiction, in the event of default of the obligor the institution is not allowed to foreclose the financial collateral. Instead, it is allowed to sell the collateral in the market and seize the proceeds. However, the institution is only allowed to sell collateral in the amount that is required settle the debt of the obligor, no more. Financial collateral is valued daily and therefore the institution can sell it in the market until the debt is settled in full. Accordingly, the amount of the synthetic holding should be the accounting value of the pledged shares limited by the limit of the EAD of the loan. We present below two scenarios where there is overcollateralization. Scenario 1 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of the institution’s own equity shares in the amount of 150 shares that are valued in the market 1 monetary unit each, for a total amount of 150 monetary units.  The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares to settle the debt and therefore the deduction should be the accounting value of 100 shares as per Q&A 2020_5128. Is the approach followed by the institution, correct? Scenario 2 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of: 100 shares of the institution own shares that are valued in the market 1 monetary unit each, for a total amount of 100 monetary units. 100 shares of another company, for the purpose of the scenario is an industrial company, that are valued at 1 monetary unit each, amounting a total of 100 monetary units. The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares in total and would sell in the market the obligor’s portfolio prorate, i.e. 50 shares of the institution and 50 shares of the shares of the industrial corporate. Accordingly, the deduction would be the accounting value of 50 shares of the institution, in line with Q&A 2020_5128. Is the approach followed by the institution, correct?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7585
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/11/2025

Deduction of pledged own shares from Common Equity Tier 1 items

Institutions, in the context of private banking and or corporate banking business, provide liquidity to investor/clients for purposes of their own commercial business (unrelated to the acquisition of the institution’s own shares). This is carried out by providing loans pledged with financial collateral in the form of equity shares, corporate bonds, sovereign debt, term deposits or cash in a sight account. Under the contractual arrangements of the loan and the pledge, as well as applicable legal regulation in our jurisdiction, in the event of default of the obligor the institution is not allowed to foreclose the financial collateral. Instead, it is allowed to sell the collateral in the market and seize the proceeds. However, the institution is only allowed to sell collateral in the amount that is required settle the debt of the obligor, no more. Financial collateral is valued daily and therefore the institution can sell it in the market until the debt is settled in full. Accordingly, the amount of the synthetic holding should be the accounting value of the pledged shares limited by the limit of the EAD of the loan. We present below two scenarios where there is overcollateralization. Scenario 1 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of the institution’s own equity shares in the amount of 150 shares that are valued in the market 1 monetary unit each, for a total amount of 150 monetary units.  The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares to settle the debt and therefore the deduction should be the accounting value of 100 shares as per Q&A 2020_5128. Is the approach followed by the institution, correct? Scenario 2 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of: 100 shares of the institution own shares that are valued in the market 1 monetary unit each, for a total amount of 100 monetary units. 100 shares of another company, for the purpose of the scenario is an industrial company, that are valued at 1 monetary unit each, amounting a total of 100 monetary units. The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares in total and would sell in the market the obligor’s portfolio prorate, i.e. 50 shares of the institution and 50 shares of the shares of the industrial corporate. Accordingly, the deduction would be the accounting value of 50 shares of the institution, in line with Q&A 2020_5128. Is the approach followed by the institution, correct?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7584
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/11/2025

The instructions for row 0170 C10.00 seem inconsistent.

The instructions for row 0170 C10.00 seem inconsistent. The title of the line item "Of which: categorised as secured by residential real estate in IRB" refers to secured by residential real estate. Whereas further instructions, "Exposures assigned under IRB approach to the exposure class 'Purchased receivables' pursuant to Article 147(2), point (d)(ii) of Regulation (EU) No 575/2013.", refers to Purchased recaivables. The article mentioned, 147(2)(d)(ii), refers to retail exposures secured by residential property.  Is our understanding correct that this row should not only be populated for Purchased receivables under the IRB approach but actually should be populated for secured by residential real estate under IRB approach?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions
  • ID: 2025_7579
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Presentation of lending for house purchase

Can loans that are directly disbursed to customers be considered as lending for house purchase?

  • 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 (repealed)
  • ID: 2025_7578
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Delimitation of the quantity of liabilities and capital instruments to be computed in the NSFR calculation

In the context of Article 428o(a) CRR, which lists liabilities and capital items subject to a 100% available stable funding (ASF) factor, how should the reference to “before the adjustments required pursuant to Articles 32 to 35, the deductions pursuant to Article 36 and the application of the exemptions and alternatives laid down in Articles 48, 49 and 79” be interpreted? Specifically, should: the Common Equity Tier 1 (CET1) items be included in full, before all adjustments, deductions and exemptions referred to in Articles 32 to 35, 36, 48, 49 and 79; or the CET1 items be taken before adjustments pursuant to Articles 32 to 35, but after the deductions defined in Article 36 and the exemptions and alternatives laid down in Articles 48, 49 and 79?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7577
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 10/11/2025

SPV repack transactions (collateral eligibility)

For recognising received financial collateral when calculating the exposure value under the counterparty credit risk (CCR) framework, does Article 207(2) CRR – which requires that the credit quality of the obligor and the value of the collateral shall not have a material positive correlation – apply?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7576
  • Topic: Market risk
  • Date of submission:

SPV repack transactions

Do SPV repackaging transaction on standardised platforms incur counterparty credit risk (CCR) or is the termination scenario considered a contractual feature that only results in market risk? If these transactions are subject to counterparty credit risk, how should the value of the collateral be taken into account?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7575
  • Topic: Market risk
  • Date of submission:

Validation rules taxonomy V4.0 C_17.01

Validation rule v23510_h incorrect

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions
  • ID: 2025_7573
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Finrep validation between F09.01.1 and F18.00 other commitments given

If we have undrawn credit facilities that based on CRR Annex I are reported under Other commitments given in F18.00 r0480 c0010, but they do not meet any of the conditions described in Annex V Part 2.105 (a-c) to be reported in F09.01.1, we cannot report them on F09.01.1 but in F18.00 only.  Validation errors  v2795_m: [F 18.00.e, F 09.01.1] {F 18.00.e, r0480, c0010} = {F 09.01, r0170, c0010} + xsum({F 09.01.1, (r0170, c0010, c0020, c0030, c0035, c0100)}) and v2797_m: [F 18.00.e, F 09.01.1] {F 18.00.e, r0500, c0010} = {F 09.01, r0200, c0010} + xsum({F 09.01.1, (r0200, c0010, c0020, c0030, c0035, c0100)})  require that Other commitments given match in both these tables. What if the conditions mentioned in Annex V Part2.105 are not met for the other commitments given in F18.00?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7569
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 16/10/2025

Disclosure on more periods in one template

In some reports of the Pillar 3 reporting obligations some cells are specifically asking for the amount of the previous periods to be declared : For instance  : Report K6000 - EU OV1 – Overview of total risk exposure amounts : Column 0020 T-1 On those reports we are having some different interpreations with some of our clients regarding what is expected to be fed in column T-1. Some of our client think that column T-1 should always refer to the end of the previous financial year, meaning that when reporting figures for Q2/Q3/Q4 2025 the figures reported in column 0020 should of report K6000 should remain unchanged and should always report the data of Q4/2024.   In our intepretation of the ITS, we understand that in case : The Entity has to report a table on a quarterly frequency in this case the T-1 figures should always reflect the figures of the previous quarter, so for closing date Q2/2025 column 020 of K6000 should be populated with figures coming from Q1 2025, so for closing date Q3/2025 column 020 of K6000 should be populated with figures coming from Q2 2025, so for closing date Q4/2025 column 020 of K6000 should be populated with figures coming from Q3 2025, The Entity has to report a table on a Yearly frequency in this case the T-1 figures should always reflect the figures of the previous year, so for closing date Q4/2025 column 020 of K6000 should be populated with figures coming from Q4 2024 Can you please indicate the correct expectation of EBA ?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 650/2014 - ITS on disclosure by competent authorities
  • ID: 2025_7567
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 26/09/2025

Is the EBA mapping file for Pillar 3 template EU CMS1 correct?

Is the EBA mapping file for Pillar 3 template EU CMS1 correct disallowing amounts to be reported on column a/row 8 and requiring items that could relate to IRB approach to be reported in column b (SA)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR
  • ID: 2025_7563
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2025

C_ 08.01.a - qx 2068 – “Retail exposures - Secured by residential real estate”

Should the retail exposures secured by residential real estate to a natural person and the retail exposures secured by residential real estate to an SME both be assigned to the exposure class of “Retail exposures secured by residential real estate” in C_08.01.a qx 2068?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions
  • ID: 2025_7561
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025