Search for Q&As

Enquirers can use various factors to search for a Q&A:

  • These include searching by the Q&A ID; legal reference, date submitted, technical standard / guideline, or by keyword if known.
  • Searches can be extended to more than one legal act, topic, technical standard or guidelines by making multiple selections (i.e. pressing 'Ctrl' on your keyboard, and selecting the relevant ones from the drop-down lists by left mouse-click).

Disclaimer:

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.

Final Q&As Q&As under review Rejected Q&As Archived Q&As All Q&As

List of Q&A's

validation rule EBA_v08988

How can we solve a breach in the v08988_m rule, when the items compared between the Funding plan template P01.02 and the FINREP F08.01 template are not compatible ? Indeed, the repurchase agreements  to be declared in P01.02 in line r010 are supposed to exclude those held for sale, but their amount is compared to the FINREP amount that includes the portion held for trading.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
  • ID: 2024_7130
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as Rejected Q&A: 31/01/2025

Maturity weighting of gross JTD amounts to calculate net JTD amounts

Are the maturity weighting of gross JTD amounts and three months floor of Art. 325x(3) applicable only to gross JTD amounts in cases where no offsetting is possible or are they applicable more generally to all gross JTD amounts?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7129
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 13/09/2024

Components included in total gross annual earnings used for the calculation of gender pay gap

Should overtime pay awarded to staff members be included in their total gross annual remuneration for the purposes of calculating the gender pay gap? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/04 - Guidelines on sound remuneration policies under CRD (repealing EBA/GL/2015/22)
  • ID: 2024_7128
  • Topic: Remuneration
  • Date of submission:
  • Published as final Q&A: 25/10/2024

Collateral requirements for the ‚another credit protection‘ alternative in the form of cash on deposit held with a third-party credit institution

Does Article 26e (10) (b) of the Amended Securitisation Regulation allow cash collateral to be provided also in the form of a guarantee or letter of credit given by a qualifying third-party credit institution?

  • Legal act: Regulation (EU) No 2017/2402 (SecReg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7127
  • Topic: Simple Transparent and Standardised securitisation
  • Date of submission:

Calculation of the GAR and BTAR flow versus the previous disclosure period

For Small and Non Complex Institution and other institution, should the GAR and BTAR flow be calculated on a semi-annual or an annual basis?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7126
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 07/01/2025

Definition of Stable Deposits in C73 Outflows

Can the EBA confirm, where customers who qualify for Transactional treatment under LCR delegated act, Article 24 1.b (ie are not captured by Article 25 Higher Outflows), with deposits held in a transactional account, ie a current account, but fail the activity criteria for Transactional accounts per Article 24 para 3 (salaries, income or transactions are regularly credited and debited respectively against that account), however pass the criteria for Established customer relationship (ie relationship >1 year), can these be treated as Stable with a 5% weighting?  Or Other with 10% weighting?

  • 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: 2024_7125
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 21/01/2025

Exposure to credit institutions in the form of derivative contracts

Should "exposure" also consider and include cash collateral held by the covered bond issuer from its swap counterparty? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7124
  • Topic: Securitisation and Covered Bonds
  • Date of submission:

EBA_v10862 (Type – Warning validation): Assets under custody ({G01.00,r0060,c0010}) should be equal to the value in FINREP ({F22.02,r0060,c0010}).

The “Custody assets” referred in FINREP 22.2 is described as “services of safekeeping and administration of financial instruments for the account of clients provided by the institution and services related to custodianship such as cash and collateral management”.  How should the word “Services” in the above definition be interpreted?  Does it mean to populate a balance only in those cases where some fee is being charged for services provided or record all custody assets irrespective of any fee that is charged or revenue being generated? Extract from Annex V 21.2. Assets involved in the services provided (22.2)285. Business related to asset management, custody functions, and other services provided by the institution shall be reported using the following definitions:  (a) ‘Asset management’ shall refer to assets belonging directly to the customers, for which the institution is providing management. ‘Asset management’ shall be reported by type of customer: collective investment undertakings, pension funds, customer portfolios managed on a discretionary basis, and other investment vehicles;  (b) ‘Custody assets’ shall refer to the services of safekeeping and administration of financial instruments for the account of clients provided by the institution and services related to custodianship such as cash and collateral management. ‘Custody assets’ shall be reported by type of customers for which the institution is holding the assets distinguishing between collective investment undertakings and others. The item ‘of which: entrusted to other entities’ shall refer to the amount of assets included in custody assets for which the institution has given the effective custody to other entities;   As the validation rule “V10862" matches 2 data points (AUM and Custody assets) which in GSII is reported in one cell under table G01.00 Row 0060 “Assets under Custody” whereas in FINREP table 22.2 there are two different cells representing it “Assets Management(by type of customer) Row 0010” & “Custody assets (by type of customer) Row 0060” , thus making the validation incorrect? Hence, please clarify as to how to interpret the validation and whether it will be updated to include Asset Management and Custody Assets in FINREP 22.2 (i.e. validation will be Asset Management + Custody Assets in FINREP 22.2 to "Assets Under Custody" in GSIB) such that the number then reported will tie back with GSIB "Assets under custody”.

  • 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: 2024_7122
  • Topic: Supervisory reporting - Other
  • Date of submission:
  • Published as Rejected Q&A: 31/01/2025

Sign Convention and aggregated rows in Template 2 of the ITS on IRRBB

Could the EBA please clarify the expected sign convention for columns 0040 to 0090 and 0110 to 0120, and the aggregation logic for rows 0540 to 0560 in template J 02.00?

  • 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: 2024_7121
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 11/07/2024

Application of article 378 for free delivery transactions

Given the requirements of article 378 and 379 CRR II, shall the institution apply the article 378 also in case of free deliveries (disciplined by article 379) or should it be applied only to DVP transactions?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7119
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 31/01/2025

Definition of "Communication Standards" under Article 30.3

a) Is ISO 20022 considered the communication standard referenced in Article 30(3) of the Regulatory Technical Standards (RTS), Commission Delegated Regulation (EU) 2018/389? b) How should NCAs ensure that ASPSPs comply with these standards, in accordance with Article 30.6 of the RTS?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2024_7118
  • Topic: Other topics
  • Date of submission:
  • Published as Rejected Q&A: 30/07/2024

Reporting of deferred tax assets on the C33.00 - Exposures to General governments template

CRR article 48 (4) requires deferred tax assets that are dependent on future profitability and arise from temporary differences (DTAs) that are not deducted from capital to be risk weighted at 250%. EBA Q&A 2013_390 clarifies that ‘net deferred tax assets which depend on future profitability and arise from temporary differences (DTAs) and which are risk weighted with 250% according to Article 48 (4) of Regulation (EU) No. 575/2013 (CRR) are assigned to the exposure class of the obligor’. ANNEX II – Reporting on Own Funds and Own Funds Requirements states that exposures risk weighted in accordance with Title II of Part Three CRR (Credit risk framework) should be included on the C33.00 - Exposures to General governments template (C33). However, DTAs are risk weighted under the ‘Own Funds and Eligible Liabilities’ section. In cases where DTAs are exposures to governments, should these be included on the C33.00 - Exposures to General governments template (C33) in column 290 and 300?

  • 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: 2024_7117
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 09/01/2025

Providing payment service via Internet banking (web-application)

Is providing payment service via Internet banking (web-application) payment initiation channel considered to be issuing of payment instruments? 

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/09 - Guidelines on authorisation and registration under PSD2
  • ID: 2024_7115
  • Topic: Authorisation and registration
  • Date of submission:

Geographical breakdown C 15 - inconsistency in parameter CEG

We would like to open a discussion regarding parameter CEG (geographical breakdown, "Country where the exposure is generated") used in corep_of report and the inconsistency of data entry for this parameter in template C 15 and templates C 9.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2024_7113
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 09/01/2025

Article 161(8) CRD

Has the EBA received a mandate from the Commission to explore whether Islamic financial sector entities are adequately covered by the CRD and the CRR? If so, has the EBA completed the report and provided a legislative proposal to the European Parliament and to the Council? If not, does the EBA have the authority to produce a report without a mandate from the Commission?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7112
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 12/09/2024

Unrated short term claim/exposure

As per CRR Article 120(para 3, subpara c), it states: "If there is a short-term assessment and such an assessment determines a less favourable risk weight than the use of the general preferential treatment for short-term exposures, as specified in paragraph 2, then the general preferential treatment for short-term exposures shall not be used and all unrated short-term claims shall be assigned the same risk weight as that applied by the specific short-term assessment." Question: What is meant by unrated short-term claims as per this paragraph? If there is a general issuer rating available, will the exposures with residual maturity of less than 3 months be classed as Unrated and not eligible for preferential risk weight treatment as per CRR Article 120 (2)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2024_7111
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/07/2024

Risk weight for Exposures in default

What risk weight should be applied to in default exposures, under the standardised approach for credit risk? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7110
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/07/2024

Determination of exposure value cap for netting sets subject to a margin agreement.

The final answer to EBA Q&A 2023_6962 states that when capping the exposure value of a margined netting set at the exposure value of the same netting set not subject to any form of margin agreement “The term NICA, included in the formula set out in Article 275(1) and defined in Article 272(12a), does not include the variation margin posted or received.”   We believe that this is an incorrect reading and could lead to significant under estimation of RWAs whenever the institution is posting significant excess collateral to its client. This can happen particularly when trades with a large MTM unwind at maturity and the collateral balance is exchange back only on T+1 basis.   Take the following example scenario. If calculating the EAD per the margined methodology the variation margin posted to the client offsets some of the MTM of the derivatives and the add-on is fully added to EAD as the multiplier remains 1.    However under the unmargined methodology if I disregard the posted collateral then the negative current replacement cost works to significantly offset the add-on and can actually result in an EAD below the EAD incurred on only the actual replacement cost/current exposure (in this example 140).   Example Scenario       MTM of Derivatives -50 Variation Margin posted to client 150 Replacement Cost (Margined) 100 Add-on (pre multiplier) 100 Multiplier 1 EAD per margined methodology 280     MTM of Derivatives -50 Variation Margin posted to client (ignored as not NICA) 0 Replacement Cost (Unmargined ignoring VM posted) 0 Add-on (pre multiplier) 100 Multiplier 0.78 EAD per unmargined methodology 109     Final capped EAD to unmargined 109   Our understanding is that the wording in Article 274(3) which says “the exposure value of a netting set that is subject to a contractual margin agreement shall be capped at the exposure value of the same netting set not subject to any form of margin agreement” instead of meaning that there is no variation margin and hence this should be completely removed in the unmargined cap calculation should actually be read in conjunction with Article 272(12a) to define that in the absence of a margin agreement there can be nothing classed as “variation margin” and therefore all collateral is part of NICA – “NICA means the sum of the volatility-adjusted value of net collateral received or posted, as applicable, to the netting set other than variation margin”.   If we follow the previous Q&A answer then we will see significant reductions in RWA which we feel are unwarranted vs the counterparty risk for netting sets which exhibit the same portfolio dynamic as in the example above. The purpose of the cap is only to ignore exposure from large threshold amounts and not to avoid exposure from large amounts of posted collateral which are still owed back 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7109
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 23/10/2024

Counting of days past due in factoring arrangements.

As for non-recourse factoring, is it correct to start the counting of days past due based on the payment schedule defined or implied in the contractual terms with the client (i.e., the party from which the factor purchases the receivables)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/07 - Guidelines on the application of the definition of default under Article 178 CRR
  • ID: 2024_7108
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2024