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List of Q&A's

Template specific instructions – field B_05.01.0020 (Type of code to identify the ICT third-party service provider)

How to report type of identification code in data field B_05.01.0020 when using codes other than LEI or EUID?

  • 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_7283
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as final Q&A: 28/03/2025

Template specific instructions – field B_02.02.0160 (Location of management of the data)

How to report data field B_02.02.0160 where the ICT service is not based or does not foresee data processing?

  • 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_7281
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as final Q&A: 28/03/2025

Template specific instructions – field B_02.02.0130 (Country of the governing law of the contractual arrangement)

How to report field B_02.02.0150 where the ICT service is not related to storage of data (B_02.02.0140 = 'No')?

  • 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_7280
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as final Q&A: 28/03/2025

Template specific instructions – field B_02.02.0130 (Country of the governing law of the contractual arrangement)

How to report field B_02.02.0130 where the ICT service is not supporting a critical or important function considering that according to the data model this data field is a primary key?

  • 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_7279
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as final Q&A: 28/03/2025

Template specific instructions - field B_01.02.0060 (LEI of the direct parent undertaking of the financial entity)

What should be reported in case the financial entity does not have a direct parent undertaking (for example, is the parent undertaking itself) or reports the register on an individual basis?

  • 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_7278
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as final Q&A: 28/03/2025

Template specific instructions – field B_01.02.0050 (Hierarchy of the financial entity within the group)

What does ‘where applicable’ mean in the title of data field B_02.01.0050?  What should be reported in this field in case the entity that is being reported in this template is not a financial entity (i.e., option 22, 23, or 24 was selected in field B_01.02.0040 for the entity type)?

  • 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_7277
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as final Q&A: 28/03/2025

Treatment of intragroup transactions in calculation of net positions and own funds requirements for foreign exchange risk

i)When calculating the entity level positions and own funds requirements under Article 325b(4), are intragroup transactions allowed to be included ? ii)Same question for Article 352(2) determination of consolidated structural position

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7276
  • Topic: Market risk
  • Date of submission:

Definition of residential/commercial immovable property in FINREP reporting under CRR3

What should be considered as ‘residential / commercial immovable property for financial reporting purposes (FINREP)? Do the definitions change under CRR3?

  • 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_7270
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 09/01/2025

Trade exposures to Qualifying Central Counterparties and collateral substitution

In case the original exposure is fully exempt from the application of the large exposure limit based on Art. 400 (1) (j) CRR as a trade exposure to a QCCP, no calculation of an exposure “after taking into account the effect of the credit risk mitigation in accordance with Articles 399 to 403” for purposes of the large exposure limit pursuant to Art. 395 (1) CRR takes place. Is accordingly a substitution of an exposure amount to the issuer of a security not required when the trade exposure to the QCCP is collateralised with the security, as the original exposure is fully exempt from the large exposure limit?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7268
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 21/01/2025

Standardised Approach Original Exposure pre conversion factors

Should all assets deducted from own funds be reported under Original Exposure pre conversion factors (C07.00 - column 0010) and hence considered as Value adjustments and provisions associated with the original original exposure (C07.00 - column 0030)

  • 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_7267
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 13/02/2025

Contradiction between the Validation Rule EGDQ_0766a and Methodology

We kindly ask for a clarification in regard to Template C34.03: EBA Validation rule EGDQ_0766a requires that the Total number of transactions in template C34.02 must be higher or equal the Total number of transactions in Template C34.03. In Template C34.03 the total is calculated by the Software (Abacus) based on the Number of deals in separate Risk categories: "Interest Rate Risk", "Foreign Exchange Risk", "Credit Risk",   "Equity Risk"  and "Commodities". 

  • 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: 2024_7266
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2025

Classification as a “specialised debt restructurer” pursuant to Article 36(5) of Regulation No 575/2013

Is it sufficient for an institution to have complied with the criteria specified in Article 36(5) of Regulation No 575/2013, as amended through Regulation (EU) 2024/1623, no later than the last day of the preceding financial year, or must the criteria have been complied with at all times during the preceding financial year, in order for an institution to qualify as a “specialised debt restructurer”?  If it should be understood as “at all times during the preceding financial year”, would it make a difference if an institution, despite having completed a full preceding financial year, underwent a complete reorganisation during that year and began fulfilling the criteria to qualify as a specialised debt restructurer from the point of reorganisation onward? Specifically, how does the interpretation of “at all times during the preceding financial year” apply in such a context? Separately, with respect to the notion of “during the preceding financial year”, if an institution on an individual basis met the criteria to qualify as a specialised debt restructurer during that period, but was deconsolidated from a group which did not meet the criteria, does the institution’s previous inclusion in that consolidated group – which failed to meet the requirements – disqualify it from achieving specialised debt restructurer status on an individual basis?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7264
  • Topic: Credit Risk – Non performing exposures / loan origination
  • Date of submission:
  • Published as Rejected Q&A: 17/02/2025

4.0 Reporting Framework - COREP_OF C02 Template

Could you kindly clarify if, in the context of map C02 , the comparison should be made with line 0036 instead of line 0010, considering that the output floor is calculated at the consolidated level and not at the contract level?

  • 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_7263
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 21/03/2025

Reporting of ESCROW accounts (or other captive accounts) in template F08.01

In which row shall be reported Escrow accounts (or other captive deposits) from non financial companies in template F 08.01 ‘Breakdown of financial liabilities by product and by counterparty sector’?  Either as being ‘Current accounts/overnights deposits’ row 0270 or as ‘Deposits redeemable at notice’ row 0290 or as ‘Deposits with agreed maturity’ row 0280?  

  • 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_7262
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 09/01/2025

Application of DORA Regulation to sub-threshold AIFMs which have chosen to opt-in to the application of the AIFMD (Art. 3(4)), if the thresholds regarding AuM referred to under Article 3(2) of AIFMD are not exceeded

Are sub-threshold alternative investment fund managers (AIFMs) as referred to in Article 3(2) of Directive 2011/61/EU (“AIFMD”), which have chosen to opt-in to the application of the AIFMD according to Article 3(4) of that Directive, captured within the scope of application of Regulation (EU) 2022/2554 (“DORA”) under Articles 2(1)(k) and 2(3)(a) of DORA, if the thresholds regarding assets under management (“AuM”) referred to under Article 3(2) of AIFMD are not exceeded by such AIFM?

  • Legal act: Regulation (EU) No 2022/2554 (DORA)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7260
  • Topic: Other DORA topics
  • Date of submission:
  • Published as Rejected Q&A: 18/02/2025

Equity instrument subject to impairment in F20.04

The instructions for reporting the column "of which: financial assets subject to impairment [...]" regarding equity instruments (see F20.04 r0040 c0012) currently leave room for interpretation about the specific definition of "subject to impairment" to be applied. In particular, we would kindly ask the EBA to clarify whether a) the respective positions should be deactivated (i.e., greyed out) because of non-applicabilityb) there is a different expectation regarding equity instruments that has not been written in the Annex yet (in particular, equity instruments are subject to the IAS 36 impairment test).

  • 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_7258
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 09/01/2025

Correlation EBA_v7336

Please, review the EBA_v7336 correlation.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7257
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 13/02/2025

Direct contributions to reserves from shareholders

Which conditions should direct contributions to reserves from shareholders meet when assessing their conformity with the criteria contained in the last subparagraph of Article 26(1) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7256
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 07/02/2025

emission allowances

Sentence 2 of paragraph 3 of Annex II CRR refers to point (11) of Section C of Annex I MiFID, i.e. to emission allowances. Does that mean that spot market emission allowances are to be treated as derivative contracts listed in Annex II, even though they are not derivative in character?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7255
  • Topic: Other issues
  • Date of submission: