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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

Reporting framework 4.0 Validation rules release (new format) (Uploaded on 19/12/2024)

Could you please confirm whether validation rule e4900_n is incorrect and should be amended by removing r0190 from the rule and validation rule v0313_m is incorrect and should be amended by adding r0210 to the rule?

  • 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_7417
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 23/05/2025

Definition of ICT service

If a supplier must provide an ICT Service to fall under DORA, how should we determine what qualifies? Should we rely on the DORA regulation’s definition of an ICT Service, or should we use the Annex 3 list (S01-S19) from the ITS Register of Information?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information
  • ID: 2025_7415
  • Topic: ICT-related incidents (management / classification / reporting)
  • Date of submission:
  • Published as Rejected Q&A: 09/07/2025

Dora agreements - ICT service supports a CIF

When an ICT Service supports a Critical and Important Function (CIF) within a financial entity, providers must sign DORA agreements with their suppliers if the supplier: a)     Provides an ICT Service (as per the DORA definition). b)     Critically underpins the ICT Service, meaning its disruption could affect security or continuity (based on ITS on Register of Information, Article 3(2)(b)). Is this interpretation correct? Or must DORA agreements be signed with all critical suppliers, even those that do not provide ICT Services?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information
  • ID: 2025_7414
  • Topic: ICT-related incidents (management / classification / reporting)
  • Date of submission:
  • Published as Rejected Q&A: 09/07/2025

Register of ICT Services

Are these listed listed types of ICT-services (e.g., S07, S11, S12) covered under DORA’s definition of ICT Services? If not, can, e.g., facilities or infrastructure that do not include data or digital elements be excluded from this definition?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information
  • ID: 2025_7412
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as Rejected Q&A: 09/07/2025

Risk Weights for International Organisations under the Standardised Approach

Is it permissible that exposures to NATO Communication and Information Agency are assigned a 0 % risk weight under Article 118(f) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7411
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 18/07/2025

Definition of landline services

What are landline services in this context? Could it include fiber optics (e.g., black fiber)?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7410
  • Topic: ICT-related incidents (management / classification / reporting)
  • Date of submission:
  • Published as Rejected Q&A: 09/07/2025

Validation rules taxonomy V4.0 C_08.01.a,C_09.02 - v1672_m

The validation rule formula v1672_m specifies that the Risk Weighted Assets (RWA) after supporting factor in column 0125 reported under form 09.02 for IRB exposure class corporates – purchased receivables of all country should be equal to RWA reported under form C_08.01.a, column 0260 where Sheet is in qAE:qx2075 (Corporates - Purchased receivables with own estimates of LGD or conversion factors). The Sheet qAE:qx2076 (Corporates - Purchased receivables without own estimates of LGD or conversion factors) should also be considered in the formula for comparison of exposure to corporates – purchased receivables (with and with-out own estimates of LGD or conversion factors). This Sheet qAE:qx2076 is also a part of validation rules v0435_m, v0436_m and v0438_m where a similar comparison is made for original exposure, Exposure at Default (EAD) and RWA pre supporting factor. The control seems incoherent. Can you please confirm the sheets which need to be included for comparison of corporates – purchased receivables between forms C_08.01.a and C_09.02?

  • 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_7409
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 23/05/2025

Validation rules taxonomy V4.0 C_08.01.a,C_09.02 - v0418_m

The validation rule formula v0418_m specifies that the Risk Weighted Assets (RWA) reported under form 09.02 for IRB exposure class central governments and central banks of all country should be less than or equal to RWA reported under form C_08.01.a, column 0255 where Sheets are in qAE:qx2021 (Central governments and central banks with own estimates of LGD and/or conversion factors), qAE:qx2020 (Central governments and central banks without own estimates of LGD or conversion factors), qAE:qx2014 (Corporates - Specialised Lending without own estimates of LGD or conversion factors), qAE:qx2055 (Retail exposures - Purchased receivables - with own estimates of LGD or conversion factors). The Sheet qAE:qx2014 and qAE:qx2055 should not be considered in the formula for comparison of exposure to central government and central bank. These two sheet’s codes are also not part of validation rule v0415_m and v0416_m where the similar comparison is made for original exposure and Exposure at Default (EAD). The control seems incoherent.

  • 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_7408
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 23/05/2025

EBA Remuneration Diversity Benchmarking - R23.00 - Reporting of not applicable (n/a) gender pay gap

What should be reported in template R23.00 if the gender pay gap cannot be calculated?

  • 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: 2025_7407
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

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

For the management body in its supervisory function and senior management in Template 44.4 column 0040, and management body in its management function in column 0030, should only the number of members of the management body and senior management in EU parent company be reported, or should the number of members of the consolidated subsidiaries also be included? Same question applies to the variable and fixed remuneration rows 0010 and 0020, and other staff expenses row 0030.

  • 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_7406
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Interaction between CRR3 article 124 and article 193

When should an IPRE exposure be riskweighted at 150% according to CRR3 article 124 para 1 (b)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7401
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

FINREP – Template 40 Group structure (40.1 “entity-by entity” – 40.2 “instrument-by-instrument”) – Notion of Group scope

Could you clarify if the associated companies whose holder is a group company that consolidates within the prudential scope by equity method should be included individually?

  • 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: 2025_7399
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Maturity floor for SFT transactions under a master netting agreement that does not fulfill the enforceability criteria of CRR Article 206.

Does the EBA recognise that Securities Financing Transactions (SFT) conducted under an industry master netting agreement (MNA) such as GMRA or GMSLA could be subject to the 5-day floor maturity under CRR Article 162(2)(d) to the extend such MNA (i) meets the requirements of CRR Article 207 (2) to (4) on the eligibility of the collateral but (ii) does not necessarily fulfill the close-out netting enforceability criteria of Article 206 due to local law and absence of robust netting legislation for instance? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7397
  • Topic: Credit risk
  • Date of submission:

Instructions for completing the register of information-Functions identification-Licenced activity

In the specifications of the DORA Register of Information file, in sheet B0601 for insurance and reinsurance undertakings, the list of values "List of possible values for all data fields with drop-downs (updated 3 March 2025)" appears, which does not include classes 17 ("Legal Expenses Insurance") and 18 ("Assistance"). Please inform us how these activities should be declared in the column "Licensed activity B06_01_0020".

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information
  • ID: 2025_7395
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as Rejected Q&A: 25/06/2025

Calculation of minimum lease payments in case of operational lease

Does the EBA acknowledge that the residual value should be discounted, or the interests on this residual value should be filtered out of the calculation of the discounted minimum lease payments, to avoid an increase of the exposure beyond the accounting value?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7393
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 21/05/2025

Multilateral development banks classification for the purpose of article 325ah

Buckets 2 and 11 of Table 4 in Article 325ah refer to the category of multilateral development banks (MDBs) and international organisations (IORGs) referred to in Article 117(2) or Article 118 of CRR. At the same time, paragraph 2 of the same article 325ah, requires the use of a classification that is commonly used in the market for grouping issuers by sector, in order to assign a risk exposure to a sector.  Assuming that such a market wide accepted classification would show a certain counterparty as an MDB, as long as this specific counterparty is not listed in the above listed articles mentioned for buckets 2 and 11 of Table 4 in Article 325ah (as a one to one match) , then this counterparty would need to be assigned to a different bucket, likely 4 or 13.  Can there be a departure from the specific list of MDBs and IORGs, as referred to in Article 117(2) or Article 118 of CRR, for the purpose of Table 4 in Article 325ah of CRR? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7391
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 27/06/2025

Valuation of non-CET1 instruments

As per the EBA REPORT ON THE MONITORING OF ADDITIONAL TIER 1 (AT1), TIER 2 AND TLAC/MREL ELIGIBLE LIABILITIES INSTRUMENTS OF EUROPEAN UNION (EU) INSTITUTIONS – UPDATE document published on the 27th of June 2024, paragraphs 145 to 151, the report advises to include the accrued interest in the amount used for the valuation of such instruments, i.e., the carrying amount in full, for prudential purposes. This however has not been included in any ITS on Corep or MREL that we are aware of. Could you please advise if this change should have a direct impact on the amounts reported in Corep or MREL, whether it is mandatory for all reporting entities and if so, starting with which reference date/reporting framework?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7389
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 03/06/2025

Obligation to maintain a register of information for FEs exempt under article 16

 Are financial entities, which according to article 16(1) in DORA are excluded from application of Articles 5 to 15, also are excluded from application of article 28 of DORA?    

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7388
  • Topic: Register of information (DORA)
  • Date of submission:

How to fill the refPeriod field of the parameters.csv file for the DORA register of information

As part of the DORA register of information packaging process, we are required to include a parameters.csv file that contains a refPeriod field. Could you please confirm what specific date should be used for the refPeriod?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information
  • ID: 2025_7387
  • Topic: Register of information (DORA)
  • Date of submission: