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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

Establishment and appointment of a CCP

Do the agents and distributors who are operating in a Member State (MS) or other MSs under the right of establishment based on Article 28 and 29 of PDS2 also fall under the scope of the Delegated Regulation (EU) 2018/1108 and are considered to be establishments (regardless of the way of the operation, distribution, e.g. tied agent or independent distributor, etc. ) under the AML regulation including the Delegated Regulation (EU) 2018/1108?

  • Legal act: Directive (EU) 2015/849 (AMLD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1108 - RTS on CCP to strengthen fight against financial crime
  • ID: 2021_5818
  • Topic: Central Contact Points (AML/CFT)
  • Date of submission:
  • Published as final Q&A: 17/03/2023

To overrule the validation error V09341_m in SBP credit risk report

Can you agree to overrule the validation error V09341_m in SBP credit risk reporting for context date of 202012?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
  • ID: 2021_5817
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as Rejected Q&A: 28/03/2022

To overrule the validation error V6205_m in SBP credit risk report

Can you agree to overrule the validation error V6205_m in SBP credit risk reporting for context date of 202012?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
  • ID: 2021_5816
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as Rejected Q&A: 28/03/2022

Large Exposures : Mismatch between ITS and DPM v3.0 - C28 column 350 / C29 column 360.

The ITS states that a percentage of Tier 1 capital should be submitted for C28 column 350 / C29 column 360, whereas the DPM only permit a monetary value.

  • 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: 2021_5814
  • Topic: Supervisory reporting - Large Exposures
  • Date of submission:
  • Published as final Q&A: 25/06/2021

Gross carrying amount of held for trading financial assets in disclosure of non-performing and forborne exposures

Does the 'Carrying amount of Financial assets held for trading' include also the 'Gross carrying amount/nominal amount Performing exposure' in Template 3: Credit quality of performing and non-performing exposures by past due days, and also in the other related templates?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2018/10 - Guidelines on disclosure of non-performing and forborne exposures
  • ID: 2021_5813
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 10/03/2023

Application of the leverage ratio exemption related to the passing-through of promotional loans to other credit institutions

Can the leverage ratio exemption related to the passing-through of promotional loans to other credit institutions (Article 429a(1)(e) CRR) be applied if an institution which is not a public development credit institution (Article 429a(2) CRR) but an entity set up by the central government, regional government or local authority of a Member State would issue promotional loans (Article 429a(3) CRR) through credit institutions and match these exposures by covered bonds on the liability side, under the same terms and conditions?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5811
  • Topic: Leverage ratio
  • Date of submission:
  • Published as final Q&A: 03/12/2021

CET1 available after meeting the entity’s requirements in case of a MPE approach

How should row 0400 ('CET1 (%) available after meeting the entity’s requirements') of Template M 02.00 of the ITS on disclosure and reporting on MREL and TLAC be filled in case of resolution groups with a multiple point of entry approach (MPE), where the resolution group is different from the prudential group?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/763 – ITS with regard to the supervisory reporting and public disclosure of MREL
  • ID: 2021_5810
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 31/03/2023

Transitional provisions under the IFR (Regulation 2019/2033)

How should the “twice the relevant own funds requirement pursuant to Chapter 1 of Title I of Part Three of Regulation (EU) No 575/2013”, referred to in article 57(3)(a) of Regulation 2019/2033 be understood?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5808
  • Topic: Prudential consolidation
  • Date of submission:
  • Published as Rejected Q&A: 25/04/2023

Validation rule v6210_m, C105.02

What rules or regulations raise the upper limits for the ratio of RWA to EAD?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2021_5809
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as Rejected Q&A: 28/03/2022

Application of the provisions described in paragraphs 10 to 12 of Article 133 (systemic risk buffer, SyRB)

How do the provisions described in paragraphs 10 to 12 of Article 133 of Directive 2013/36/EU (CRD) apply when a Member State (MS) sets a domestic systemic risk buffer (SyRB) rate on all or some of the relevant exposures of that MS and, additionally, wants to recognize a SyRB rate activated by another MS, which applies to the same exposures (or some of them)?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5801
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 18/03/2022

Meaning of ‘pure industrial holding company’ in the definition of financial institution.

How should the term ‘pure industrial holding company’ be understood in the context of the definition of ‘financial institution’ in accordance with article 4(1)(26) CRR? Would a holding company, the investments of which are exclusively outside of the financial sector, qualify as ‘purely industrial’ for the purposes of that definition?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5798
  • Topic: Own funds
  • Date of submission:

CET 1 Minority Interest Calculation and Forex conversion of non-EU subsidiary’s financial statements

Regarding minority interests calculations: 1) Should the Common Equity Tier I items of the subsidiary referred to in Article 81(1) and 84(1)(a) CRR be calculated according to the local accounting framework or according to the consolidated applicable accounting framework, when the two frameworks differ? 2) Should the Other Comprehensive Income that arises from the currency conversion of the local financial statements to the Group’s reference currency be considered in the minority interest computation?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5795
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 31/03/2023

How to report liabilities with notice period in C69.00 and C70.00

How can evergreen repos be reported in the C69.00 template? How can deposits with notice period > 1 day be reported in the C69.00 and C70.00 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: 2021_5794
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 10/09/2021

Disclosures of Staff expenses Management body in its supervisory function in FINREP Template 44.4

In the countries where we operate supervisory board and management board are two separate bodies. The supervisory board also has members which are not employed by the reporting entity but still receive remuneration for their function. We would like to understand, if this remuneration has to be presented in template 44.4 column 0040 and if yes, should those external remuneration be presented consequently in staff expenses (FINREP Template 2 - Statement of profit or loss in a r370, c010 )?

  • 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: 2021_5793
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 10/09/2021

Combined buffer requirement on top of MREL consolidation level

Assuming that the consolidated resolution group level pursuant to Article 45c (3) BRRD does not correspond to the prudential consolidation level in accordance with Article 11 CRR, which consolidation level is relevant in terms of distribution restrictions according to Article 16a BRRD?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5792
  • Topic: MREL
  • Date of submission:
  • Published as Rejected Q&A: 09/06/2023

Supervisory Benchmarking Exercise, Annex VI, C107.01, row 0010, column 0020

Is row 0010, column 0020 of C107.01, as specified in Annex VI expected to be filled in as compulsory field?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2021_5791
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as Rejected Q&A: 28/03/2022

Applicability of fix amount dividend policy to mutuals, cooperative societies, saving institutions and similar institutions

Is Q&A 4731 applicable to mutuals, cooperative institutions, savings institutions and similar institutions?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions
  • ID: 2021_5787
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Underlying exposures of securitisations and calculation of the applicable amount of insufficient coverage for NPE for the purpose of calculating deductions from CET1 items

Are underlying exposures of a traditional or synthetic securitisation, for which the originator has either: i) achieved Significant Risk Transfer (SRT) as per Article 244(1)(a) or Article 245(1)(a); or ii) following the full deduction approach as per Article 244(1)(b) or Article 245(1)(b) in or out of scope of the minimum loss coverage requirement for non-performing exposures (see Article 36(1)(m) and Article 47a CRR)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5785
  • Topic: Credit Risk – Non performing exposures / loan origination
  • Date of submission:
  • Published as final Q&A: 03/03/2023

Elaboration of the template EU LIQ2 using supervisory data EBA/ITS/2020/04 - Annex XIII - Template EU LIQ2: Net Stable Funding Ratio

There seems to be inconsistencies at the level of the mapping tool for the elaboration of the template EU LIQ2 using superviosry data: specifically, while in CoRep templates C80 and C81 the assets/liabilities with no maturity are included in the "less than 6 months maturity" band, in the disclosure template these items are requested separately. This is inconsistent with the indications provided by the mapping tool: can the mapping tool be ignored?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5782
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 29/04/2022