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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

Counterparty classification of CCP

Where counterparty sector breakdown applies, it is required more guidance on how to classify a CCP which have the banking license. For instance, in template F10, where should we report derivatives positions we have with a QCCP which at the same time is (i) a clearing house and (ii) a credit institution (included in the list of ECB’s supervised banks)? We face the ambiguity in classification in further reporting frameworks both supranational (e.g. G-SIB data collection exercise, FSB)  and local (i.e. Circolare 262 Banca d’Italia on Financial Statements).

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)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_7316
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/03/2025

RWA in COREP C43

In COREP C43, which RWA should be reported? In particular, should RWA be reported with or without taking into account the derogations (transitional measures) impacting RWA in CRR3?

  • 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_7315
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as Rejected Q&A: 28/04/2025

C01.00 - CIU deduction from own funds

Where in the sheet C01.00 of the COREP, can we deduct CIUs under fallback approach (subject to 1250% RWA) from CET1 (as permitted by article 36.1.k.vi) since no dedicated caption is currently foreseen?

  • 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_7314
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 21/03/2025

Part 2 – Template specific instructions to template B_06.01

Data point B_06.01.0050 is missing from the official ITS templates. Is this data point no longer applicable?

  • 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_7313
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as final Q&A: 28/03/2025

DPM 400 - Modelisation of report C1000

we have a suspicion of schizophrenic modeling on the new C1000 report.  Indeed on this report when we look at the annotated templates it seems that all cells from column 0090 are sharing the same XBRL address as their corresponding cell for the same row from column 0100. Which means that from a technical point of view we will only be able to submit one “amount” per pair of cells C0090/C0100 for a dedicated row. For instance the Annotated templates stats that : {C_10.00, r0060, c 0090, s0000}=={C_10.00, r0060, c 0100, s0000} VariableID 3295841 VariableVID = 3295841    In the same time when we look at the ITS : We understand that may be possible that the transitional provisions do not apply  and so that or instance amount reported in cell 0020 _ 0090 can be equal to the amount in cell  0020 _ 0100 where the amount expected  for both cell is zero.  But we do expect from our understanding of the ITS that the transitional provision may apply and that the impact should be reported in various rows. In this case we will need to report different amounts on a specific row for those two columns, which seems unfeasible with the current setting.   Do you agree with our understanding?    

  • 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_7312
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 21/03/2025

Regulatory technical standards - subcontracting ICT services supporting critical or important functions

Where and when was the Comission Delegated Regulation (EU) supplementing Regulation (EU) 2022/2554 of the European Parliament and of the Council with regard to regulatory technical standards to specify the elements which a financial entity needs to determine and assess when subcontracting ICT services supporting critical or important functions as mandated by Article 30(5) of Regulation (EU) 2022/2554 oficially published? 

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7310
  • Topic: Other DORA topics
  • Date of submission:
  • Published as Rejected Q&A: 17/03/2025

ANNUAL REPORT ON NEW ARRANGEMENTS ON THE USE OF ICT SERVICES

Does Article 28(3) DORA require a separate and specific communication in addition to the Register of Information, or whether the communication of such data is already fulfilled through the annual submission of the same Register, constituting a single compliance obligation? In the event that a separate communication is required in addition to the annual submission of the Register of Information, what is the meaning of the term 'categories of third-party ICT service providers'?

  • 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_7309
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as final Q&A: 14/08/2025

Validation rule v22095_h in Reporting Framework 3.5

The question concerns the EBA Reporting Framework 3.5, Validation Rules (19 December 2024), rule v22095_h. This rule require that total amounts of Loans and Advances should be equal to the sum of sub-total amounts (Retail, Wholesale non-financial, Wholesale financial) in the context of Reporting on interest rate risk in the banking (specified in Section 12 – ‘Reporting on interest rate risk in the banking book’ of Annex I to Regulation (EU) 2024/3117, form J02.00 : {r0050} = +{r0080} + {r0100} + {r0110}Is the formula correct having in mind the possibility to have exposures from clients that do not satisfy definitions of sub-categories but have to be reported in "Loans and Advances"? 

  • 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_7308
  • Topic: Supervisory reporting - IRRBB
  • Date of submission:
  • Published as Rejected Q&A: 28/04/2025

Treatment of two-legs derivatives and validation Rule EBA V16337 (Tab J0200)

Could you please clarify the sign of the carrying amount for derivatives in J0200 ?

  • 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_7307
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 26/06/2025

Validation Rule EBA_v22095 (tab J0200) : Duration

Could you please deactivate the validation rule EBA_v22095 for IRRBB reporting ? This validation rule checks that the sum of the modified durations for the sub-categories Retail, Wholesale Non-Financial, Wholesale Financial equals the modified duration of the Loans and Advances category. However, modified duration is not an additive measure.

  • 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_7306
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 26/06/2025

Computation of the secured part of Non-IPRE according to Art.125(1)

In the computation of the secured part of Non-IPRE exposures, should senior liens from banks within the same group be taken into account?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7305
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 21/02/2025

Report charges and rejections

Hello, when will you publish the report specification result of the consultation ?

  • Legal act: Regulation (EU) 2024/886 (IPR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7304
  • Topic: Instant payments
  • Date of submission:
  • Published as Rejected Q&A: 28/08/2025

Internal Model Method

What is the prudential treatment of cash flow spikes in the calculation of own funds requirements for counterparty credit risk under the Internal Model Method?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7303
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 21/05/2025

Treatment of feature of tranching for mortgage backed securities

With regards to agencies pools and TBAs, since these are not really tranche product because they are backed by the US government, should they be considered more like a non securitized product rather than securitized product under the SBA?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1423/2013 - ITS on disclosure of own funds requirements
  • ID: 2025_7302
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 17/02/2025

Other commitments received - calculation of guarantee amounts

On report F09.02, banks are asked to report guarantees received as collateral, partly in column 0010 and partly in column 0020. Where some questions have been answered in earlier Q&As, some questions remain: Based on Q&A 2013_214, guarantees received on off-balance sheet exposures should be reported as "Other Commitments Received". These are reported in F09.02 Col0020.Based on Q&A 2023_6773, in F09.02 Col0010, guarantees are considered by ignoring other collaterals.Should other collaterals be considered in calculating the amount reported in column 0020? Along the same lines, how should calculations work for both columns 0010 and 0020 if multiple guarantees are received? Within the same group of exposures and its/their contractually linked collaterals/guarantees, should they all be calculated separately and independently, ignoring the existence of other guarantees within the same group similar to the way other collaterals in the same group are ignored?The ITS states that "For other commitments received, the nominal amount shall be the total amount committed by the other party in the transaction." is to be reported in column 0020.  Does this also apply in the case whereby a guarantee is received to secure an (off-balance) exposures? In other words, should it be capped at the Off-Balance Exposure Amount or not?

  • 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_7301
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/03/2025

Definition of financial institution under Article 4(1)(26)

Does the definition of financial institution under Article 4(1)(26) CRR include trust companies under Liechtenstein law?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7300
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 21/01/2025

Definition of ancillary services undertaking under Article 4(1)(18)

Does the definition of ancillary services undertaking under Article 4(1)(18) CRR include trust companies under Liechtenstein law?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7299
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 21/01/2025

Remittance date for quarterly iMREL/iTLAC Q1 2025

Will the remittance date for Q1 2025 iMREL/iTLAC reporting be aligned to the due date for COREP reporting for which the submission date is postponed to June 2025?

  • 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: 2025_7298
  • Topic: MREL
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2025

The scope of the regulation described in Article 6 mismatches what is presented as an option in the Annex I, Part 2 of the same regulation

Do financial entities must include non-financial entities within the same group in the Register of Information? If not, why is there an option to do so?

  • 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_7297
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as final Q&A: 25/07/2025

Validation Rule for Marginal Impact of Reintegration of CVA Exemptions

The guidance for the population of rows 0040-0110 specifies that firms should populate the marginal impact of reintegration of CVA exemptions "separately for each exemption". However there is a warning validation rule v23083_m which specifies that the sum of the individual exemptions should be equal to the total "{r0040} = {r0050} + {r0060} + {r0090} + {r0100} + {r0110}". We would like to query whether the validation rule is valid and therefore whether we should be calculating a single CVA exemption reintegration impact of excluded transactions and then attributing by type of exemption or genuinely calculating the marginal impact separately by type of exemption. 

  • 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_7295
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 26/02/2025