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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

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

a) The “Custody assets” referred in FINREP 22.2 is described as “service of safekeeping & 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 the word “Service” in above definition needs to be interpreted? Does it mean to populate balance only in those cases where some fee is being charged for services provided or record all custody assets irrespective of any fee is charged /revenue being generated? 21.2. Assets involved in the services provided (22.2)285. Business related to asset management, custody functions, and otherservices provided by the institution shall be reported using the followingdefinitions:(a) ‘Asset management’ shall refer to assets belonging directly to thecustomers, for which the institution is providing management. ‘Assetmanagement’ shall be reported by type of customer: collective investmentundertakings, pension funds, customer portfolios managed on adiscretionary basis, and other investment vehicles;(b) ‘Custody assets’ shall refer to the services of safekeeping andadministration of financial instruments for the account of clients providedby the institution and services related to custodianship such as cash andcollateral management. ‘Custody assets’ shall be reported by type ofcustomers for which the institution is holding the assets distinguishingbetween collective investment undertakings and others. The item ‘of which:entrusted to other entities’ shall refer to the amount of assets included incustody assets for which the institution has given the effective custody toother entities; b)    As the validation rule “V10862" matches 2 data points (AUM and Custody assets) which in GSIB 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) 2024/3117 - ITS on supervisory reporting of institutions
  • ID: 2025_7320
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 28/02/2025

Period to comply with the limit referred to in Article 37 regarding concentration risk and exposure value excess.

What limit does it refer Art. 38 (2) when it states that “Competent authorities may grant the investment firm a limited period to comply with the limit referred to in Article 37”? 

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7319
  • Topic: Concentration risk
  • Date of submission:
  • Published as Rejected Q&A: 19/03/2025

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

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)
  • 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)
  • 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

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

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

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

Applicability of DORA and TFR requirements to VASPs

Do the requirements of the Digital Operational Resilience Act (DORA) and the Transfer of Funds Regulation (TFR) apply to Virtual Asset Service Providers (VASPs) that are not classified as Crypto-Asset Service Providers (CASPs) under the Markets in Crypto-Assets Regulation (MiCAR) as of December 30, 2024 and are benefiting from the MiCAR transition period?

  • Legal act: Directive 2022/2556/EU (DORA)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7291
  • Topic: Other DORA topics
  • Date of submission:
  • Published as Rejected Q&A: 17/03/2025

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

In light of the validation rules release (new format) published on 19 December 2024 on your website, we have identified potential issues with the following validations: Validation v0329_m: This rule checks that the value in COREP template C_07.00.a, column 0220, equals the sum of columns 0215, 0216, and 0217. However, the ITS stipulates that column 0215 reflects values before currency mismatch, columns 0216 and 0217 represent adjustments for supporting factors, and only column 0220 should account for currency mismatch adjustments. The validation v0329_m appears to disregard the intended adjustment logic for currency mismatch, making the rule inconsistent with the ITS requirements. Validation v0407_m: This rule checks that the value in COREP template C_09.01.a, column 0090, equals the sum of columns 0080, 0081, and 0082. The ITS specifies that columns 0080–0090 in C_09.01.a should correspond directly to columns 0215–0220 in C_07.00.a. Given that column 0220 in C_07.00.a includes adjustments for currency mismatch, the requirement for column 0090 to equal the sum of columns 0080, 0081, and 0082 is contradictory to the ITS logic. Based on these observations, we believe that both validations, v0329_m and v0407_m, are incorrect. We kindly request your confirmation and guidance on this matter, including any planned revisions to these validations.  

  • 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_7289
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2025

Applicability of Regulation (EU) 2022/2554 (DORA) to ICT services provided by financial entities.

Clarification is needed on whether financial institutions providing ICT services to other financial institutions – regardless of whether these services are ancillary to regulated financial activities – can be qualified as ICT third-party service providers under Regulation (EU) 2022/2554. If they are, must their contractual relationships comply with the mandatory provisions outlined in Article 30 of the mentioned Regulation or are these requirements inapplicable since such entities are already authorised/licenced/registered? 

  • Legal act: Regulation (EU) No 2022/2554 (DORA)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7288
  • Topic: Other DORA topics
  • Date of submission:
  • Published as Rejected Q&A: 17/03/2025

C14.00 - v7364_m - Type of Assets (column 0160)

According to EBA Q&A 2023_6864 the validation rule v7364_m is not in line with the current regulatory provisions and shall be deleted. However, in the latest revised list of ITS validation rules as per September 2024 the rule is still active. Could you please amend the validation rules and deactivate the rule as per the above mentioned Q&A.

  • 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_7287
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2025

Template specific instructions – primary keys

How to report data fields in case of missing values?

  • Legal act: Regulation (EU) No 2022/2554 (DORA)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information
  • ID: 2024_7285
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as final Q&A: 28/03/2025

Template specific instructions – field B_05.02.0060 (Identification code of the recipient of sub-contracted ICT services)

How to report data field B_05.02.0060 if the ICT third-party service provider is a direct provider (rank =1)?

  • Legal act: Regulation (EU) No 2022/2554 (DORA)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information
  • ID: 2024_7284
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as final Q&A: 28/03/2025