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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

BTAR voluntary disclose and DPM templates

Regarding the generation of DPM templates containing ESG pillar 3 disclosure, included in reporting framework 3.3 for the ad-hoc collection, according to Commission Implementing Regulation (EU) 2022/2453, template 9 – Mitigating actions: BTAR- was required for December 24 submission only on a voluntary basis.  In case a bank has decided not to publish BTAR template in the Pillar 3 disclosure for December 2024, our understanding is that there is no obligation to deliver, for December 2024, these templates (D 09.01, D 09.02.a, D 09.02.b, D 09.02.c, D 09.02.d, D 09.03.a, D 09.03.b) included in reporting framework 3.3 to keep both reports aligned (Pillar 3 disclosure, made public in February 2025, and the reporting framework 3.3 templates). Please confirm that our view on this subject is correct.

  • 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_7424
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 11/07/2025

Risk weighting attributed to gold in the form of a commodity

Is the definition of 'gold bullion', as recently amended by Regulation (EU) 2024/1623, consistent with the previous definition of 'gold' under Regulation (EU) No 575/2013 (CRR), as clarified by EBA Q&A 2016_3011, in the sense that it includes all forms of gold commodities (such as bars, ingots, jewels, manufactured products, and coins) whose value is determined exclusively by gold content—defined by purity and mass—regardless of their form, provided that no numismatic, artistic, branding, or other extrinsic value is attributed?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7423
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 01/05/2025

Clarification on Risk Weight Assignment for ADC Exposures in Default

Could you please clarify what risk weight should be applied to ADC exposures that are in default?

  • 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_7419
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 21/05/2025

Reporting framework 4.0 Validation rules

Could you please confirm whether validation rule v23722_m is incorrect and should be amended, as it only counts time buckets greater than 7 years, which appears inconsistent with the ITS requirements?

  • 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_7418
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 23/05/2025

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

Identificación entidad financiera responsable del reporte DORA - Identification of the financial entity responsible for the DORA reporting

  ¿Si nuestra empresa no dispone de LEI, debemos informarla mediante el código europeo? ¿Qué diferencia existe entre las celdas B_01.01_0010 y B_01.02_0010 ? If our company doesn't have an LEI, should we report it using the European code? What's the difference between cells B_01.01_0010 and B_01.02_0010?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7403
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as Rejected Q&A: 31/07/2025

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