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List of Q&A's

Clarification of ETV calculation for mortgages securing more than one exposure

Article 124 paragraph 6 Regulation (EU) No 575/2013 (CRR) specifies the calculation of ETV for IPRE exposures. In order to calculate ETV, the gross value of an exposure should be divided by the value of property. Additionally, this article clarifies that: “For the purposes of the first subparagraph, point (a), where an institution has more than one exposure secured by the same immovable property and those exposures are secured by liens on that immovable property that are sequential in ranking order without any lien held by a third party ranking in-between, the exposures shall be treated as a single combined exposure and the gross exposure amounts for the individual exposures shall be summed up to calculate the gross exposure amount for the single combined exposure.” Our question refers to calculation ETV for joint mortgages – so the mortgage which secures more than one exposures and additionally these exposures may have other mortgages assigned. Based on the above, it’s clear that numerator should include the gross value of all exposures secured by this joint mortgage. Nevertheless, it’s unclear which value should be used in the denominator of ETV in the real life example described below.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7922
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 06/07/2026

Definition of "main business" under CRR

How are banks to interpret the concept of "main business" in Article 411(1) of Regulation (EU) No 575/2013 (CRR), read in conjunction with Annex I of Directive 2013/36/EU and Article 3(9) of Commission Delegated Regulation (EU) 2015/61? In particular: can an entity be considered to perform Annex I CRD activities as its "main business" within the meaning of Article 411(1) CRR if: there is an absence of any third-party commercial activity i.e. entity does not offer financial services to any external party for commercial consideration nature of the entity’s operations is ancillary to the group and it exists solely as an instrument of the group's non-financial operations with no independent commercial purpose

  • 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: 2026_7921
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 06/07/2026

Reporting obligations under Article 3 of the CIR

Whether, and to what extent, will the reporting obligations concerning Relevant Legal Entities (RLEs) under Article 3 of the CIR also apply where a recently acquired RLE is expected, with a high degree of certainty, to cease to exist as a legal entity prior to the adoption of the resolution plan as a result of a legal merger. Additionally, how should this acquired entity be treated for the purposes of resolution planning and related reporting obligations during the interim period between its acquisition and its absorption through merger? We wonder if resolution authorities (RAs) may waive the reporting obligations for this acquired entity for the first reporting cycle after acquisition. Against this background, does the framework require or allow a reclassification of the acquired entity (which used to be a Liquidation entity before acquisition with no reporting obligations) as an RLE immediately upon acquisition, implying inclusion in the group’s resolution plan and submission of the applicable reporting templates? Alternatively, may the acquired entity continue to be treated as a liquidation entity until the legal merger is completed, with its status and standalone reporting obligations remaining unchanged during the interim period? Clarification is sought on whether, in the context of M&A transactions, resolution authorities are expected to adjust the entity’s classification upon acquisition, or whether they may maintain the pre-acquisition status until legal integration is finalised.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7918
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Definition of “Substitutability” of CCPs and the connected reporting of “Alternative Providers” for the purpose of the template Z 09.04 (RESOL II).

Should the concept of substitutability of CCPs, and consequently the identification of alternative providers to be reported in template Z 09.04, be interpreted restrictively, i.e. limited to CCPs or intermediaries that are capable of providing an equivalent clearing service for the same trading venue and/or market(s)? Or should a broader interpretation of substitutability be applied, focusing on the economic function, business and regulatory objectives as well as the post-trade nature of the clearing service, under which a CCP might be substitutable not only by a concurrent CCP active on the same market, but also by: the substitution of the entire trade value chain (e.g. trading venue – CCP – CSD or trading venue – CSD); or the use of an intermediary/broker capable of rerouting either the trading and clearing activity or the transactions executed on behalf of the reporting institution through alternative FMIs, provided that such arrangements achieve a comparable economic and functional outcome for the reporting institution.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7912
  • Topic: BRRD Reporting
  • Date of submission:

Treatment of the Right Way Risk in Call Warrant

Is a call warrant issued by the counterparty  that is also the issuer of the underlying shares exempt from counterparty credit risk requirements?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7911
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Validation Rule RRCOROF_V903610_H_C0030

Could you please clarify the validation rules newly introduced or reactivated in template C34.03 within COROFI and COROFC as of 31 March 2026? These rules require that the totals for Number of Transactions (RRCOROF_V903610_H_C0030_S0001), Nominal Amount (RRCOROF_V903610_H_C0040_S0001), Positive Market Value (RRCOROF_V903610_H_C0050_S0001 ) and Negative Market Value (RRCOROF_V903610_H_C0060_S0001)  and Add-on (RRCOROF_V903610_H_C0070_S0001) equal the sum of the respective risk categories (Interest Rate Risk, Foreign Exchange Risk, Credit Risk, Equity Risk, Commodities Risk, Other).     

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7910
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 31/08/2026

Incorrect Quality Control check EGDQ_0764 for Annex I, INSTRUCTIONS FOR REPORTING ON SPECIFIC REQUIREMENTS FOR MARKET RISK, Template ({C90.00,r0010,c0080})

Data Quality ID EGDQ_0764 should be disabled as Total Assets reported in FRTB ({C90.00,r0010,c0080}) does not correspond to the amount reported in FINREP ({F01.01,r0380,c0010})

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/453 - ITS with regard to the specific reporting requirements for market risk
  • ID: 2026_7906
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Template F 13.2.1.c VariableID 433471 and 433464

Following the most recent update to the FINREP validation framework under Reporting Framework 4.2., a new data point categorization has been introduced affecting template F 13.2.1.c, specifically Variable IDs 433471 and 433464. We would appreciate confirmation as to whether this data point categorization has been correctly defined and, if so, clarification on the prudential reporting rationale underlying it. Our concern is that the validation may not be conceptually appropriate in all cases, as not all additions of foreclosed assets necessarily qualify as non-current assets held for sale.

  • 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: 2026_7904
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 05/08/2026

Exemption from deduction of Equity Holdings in an insurance company from CET1

Institution “A” currently applies the exemption provided under Article 471 CRR, whereby it does not deduct from its own funds a qualifying shareholding held in Insurance Undertaking “C” for an amount not exceeding the amount held in CET1 instruments issued by that Insurance Undertaking as of December 31, 2012 . Following the completion of a merger by absorption between Institution “A” and Institution “B” – as a result of which Institution “B”, as surviving entity, becomes the direct holder of the shareholding in Insurance Undertaking “C” by virtue of universal succession – is Institution “B” entitled to continue to apply the exemption under Article 471 CRR, as previously applied by Institution “A” in respect of such shareholding? Upon completion of the merger mentioned in question 1 above, would Institution “B” be entitled to apply the exemption under Article 471 CRR on a consolidated basis in case its direct shareholding in Insurance Undertaking “C” is transferred (as a result of a partial de-merger) to its wholly owned subsidiary Institution “D”, given that the shareholding in Insurance Undertaking “C” would in any event be held within the consolidation perimeter of Institution “B”? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7903
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 06/07/2026

Classification of of CRR PSE under Finrep where local regulators identify them as a "non-CRR Bank"

Can a CRR PSE entity that qualifies as a Credit Institution under Article 4 of the CRR, be classified as a Credit Institution under FINREP, even if the local regulator classifies them as a "non-CRR Bank"?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7897
  • Topic: Supervisory reporting
  • Date of submission:
  • Published as Rejected Q&A: 22/09/2026

RESOL1 - how balance of cash collateral received as variation margin for intra group Repurchase Agreements should be reported in Z11.00 and Z02.00

How cash collateral received as variation margin for intragroup Repo trades be reported in Z11.00 and Z02.00 when the underlying Repo has already matured? What should be the insolvency ranking (c0030) of this balance intragroup variation margin in Z11.00?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7895
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 18/09/2026

Requirement for a consolidated ICARA process under Directive (EU) 2019/2034

Does Directive (EU) 2019/2034 require investment firms that are subject to prudential consolidation under Article 7 IFR to prepare, maintain and document an ICARA process on a consolidated basis? In particular, does Article 25(4) IFD impose an obligation to perform the ICARA at consolidated level, or does it merely extend the application of Part Three without creating a standalone consolidated‑ICARA requirement?

  • Legal act: Directive (EU) 2019/2034 (IFD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7891
  • Topic: Supervision of investment firm groups
  • Date of submission:
  • Published as Rejected Q&A: 15/06/2026

Application and interpretation of the 50% / 80% weighting of positive changes under IRRBB SOT

How should Article 4(l) of the RTS on Supervisory Outlier Tests be interpreted in relation to the weighting of positive changes, in particular regarding: Whether the 80% weighting factor and associated cap should apply to EUR, given that EUR is not an ERM II currency. Whether the reference to “absolute value of negative changes in EUR or ERM II currencies” when calculating the cap should be interpreted as a sum of negative changes across all currencies or as a minimum reference between EUR and ERM II currency buckets. Whether the weighting of positive changes should be applied at the individual risk level or at an aggregated level?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7886
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:

C08.01 - EBA VR v4757_m

The EBA Validation Rule v4757_m applicable to the C08.01 template states that the column c0280 (Expected loss) shall be lower or equal to the column 0020 (Gross exposure).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7882
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

C08.01 - EBA VR v10667_m

The EBA Validation Rule v10667_m applicable to the templates C.08.01 and C.08.02 COREP templates states that the Exposure-weighted average maturity value (days) of C.08.01 (column 250) of the row 70 (Exposures assigned to obligor grades or pools) multiplied by the total of the column 110 of C.08.02 (Exposure value) must be equal to the sum of the Exposure-weighted average maturity value (days) of C.08.02 (column 250) multiplied by the sum of the Exposure value of C.08.02 (column 110).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7881
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

C09.02 - EBA VR v903627_h

The EBA Validation Rule v903627_h applicable to the C09.02 template states that the row 0030 (Corporates) shall be equal to row 0050 (Of which: SME) plus the row 0051 (Of which: Large Corporates) for almost all the columns of the template.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7875
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

EBA validation v23089_m does not allow values

EBA validation v23089_m states: with {tC_10.00, (r0010, r0020, r0040, r0050, r0060, r0070, r0080, r0090, r0100, r0101, r0110, r0120, r0130, r0131, r0132, r0150, r0151, r0152, r0153, r0154, r0155, r0156, r0157, r0158, r0159, r0160, r0161, r0162, r0163, r0170, r0230, r0240, r0250, r0260), default: null, interval: false}: isnull({c0120}) The validation only allows values in rows r0180, r0190, r0200, r0210, r0220, r0230 and r0270, while CRR IRB-IMM exposures, calculated based on SA, can be split over many exposure classes (r0040 to r0240). However this validation rule does not allow amounts to be reported in r0040-r0240 in c0120. We believe this is a mistake.

  • 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: 2026_7873
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

Validity of validation rule v10667

Validation rule v10667 seems invalid. with {default: 0, interval: true}:      sum(          {tC_08.01.a, r0070, c0250}          [where qEEA in {              [eba_qAE:qx2013], [eba_qAE:qx2015], [eba_qAE:qx2021], [eba_qAE:qx2071],              [eba_qAE:qx2073], [eba_qAE:qx2075], [eba_qAE:qx2022], [eba_qAE:qx2012],              [eba_qAE:qx2014], [eba_qAE:qx2018], [eba_qAE:qx2020], [eba_qAE:qx2072],              [eba_qAE:qx2074], [eba_qAE:qx2076]          }]      )      *      sum(          {tC_08.02, c0110}          [where qEEA in {              [eba_qAE:qx2013], [eba_qAE:qx2015], [eba_qAE:qx2021], [eba_qAE:qx2071],              [eba_qAE:qx2073], [eba_qAE:qx2075], [eba_qAE:qx2022], [eba_qAE:qx2012],              [eba_qAE:qx2014], [eba_qAE:qx2018], [eba_qAE:qx2020], [eba_qAE:qx2072],              [eba_qAE:qx2074], [eba_qAE:qx2076]          }]      )      =      sum(          {tC_08.02, c0250}          [where qEEA in {              [eba_qAE:qx2013], [eba_qAE:qx2015], [eba_qAE:qx2021], [eba_qAE:qx2071],              [eba_qAE:qx2073], [eba_qAE:qx2075], [eba_qAE:qx2022], [eba_qAE:qx2012],              [eba_qAE:qx2014], [eba_qAE:qx2018], [eba_qAE:qx2020], [eba_qAE:qx2072],              [eba_qAE:qx2074], [eba_qAE:qx2076]          }]      )      *      sum(          {tC_08.02, c0110}          [where qEEA in {              [eba_qAE:qx2013], [eba_qAE:qx2015], [eba_qAE:qx2021], [eba_qAE:qx2071],              [eba_qAE:qx2073], [eba_qAE:qx2075], [eba_qAE:qx2022], [eba_qAE:qx2012],              [eba_qAE:qx2014], [eba_qAE:qx2018], [eba_qAE:qx2020], [eba_qAE:qx2072],              [eba_qAE:qx2074], [eba_qAE:qx2076]          }]      ) We have encountered an error on this check which seems to be caused by the accuracy of the metric involved. c0250 in C08.01 and C08.02 is requested as a whole number. This causes rounding to be applied at the global (across obligor grades) level for C08.01, but at the level of C08.02 the rounding is done per obligor grade. This introduces differences between the results of the left and right side of the validation rule.  

  • 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: 2026_7872
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

Validation rules taxonomy V4.2 C09.02 v903627_h

In the latest set of EBA validations rules, VR v903627_h has been added effective 31/03/2026. This validation rule is identical to the earlier deactivated v23650_h. Via 2025_7323 it was earlier raised that v23650_h is not correct. Hence, we feel that the same applies to v903627_h. 

  • 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: 2026_7864
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

Incoherent formulae of the validation rule v22949_m

Is the formulae of the validation rule v22949_m coherent?

  • 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: 2026_7863
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026