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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.

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.

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List of Q&A's

Definition of a financial institution as regards the application of the Delegated Regulation

Is an institution, that is a subsidiary of a holding company which, in turn, owns several financial subsidiaries, not considered as a group for the purposes of the Delegated Regulation, since their parent company does not fall within the definition of a financial entity set out in Article 3 of Directive (EU) 2015/849 (AMLD)?

  • Legal act: Directive (EU) 2015/849 (AMLD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2019/758 – RTS on implementation of group wide AML/CFT policies in third countries
  • ID: 2020_5310
  • Topic: Third country policy
  • Date of submission:

Reporting of International Organizations not treated as sovereign in template C43

Should exposures to International Organizations not treated as sovereign be included in Row 160 of template C43?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2020_5309
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Fair value changes of the hedged items in portfolio hedge of interest rate risk in Prudent Valuation

How should fair value changes of the hedged items in portfolio hedge of interest rate risk be reported in the context of Prudent Valuation in COREP C 32.01?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2020_5303
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Failed XBRL rule v5713_s: [F 46.00 (r100;110;140, c010;020)] {F 46.00} <= 0

Can we keep our reporting for 2019 as it is and will row 130, column 20 be opened for this purpose? We think that this is correct presentation.

  • 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: 2020_5301
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Original maturity for off-balance sheet items

How is the „original maturity” identified for items in CRR Annex 1 (2)(b)(ii)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5297
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Risk weight for the credit risk of third countries with supervisory and regulatory arrangements at least equivalent to those applied in the Union according to Article 114(7) CRR

If an institution has an exposure to a third country which has supervisory and regulatory arrangements at least equivalent to those applied in the Union (such as Turkey) but do not have fully corresponding liabilities denominated in that currency to cover the entire exposure, what risk weight for the credit risk should assigned to the exposure of this country?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5294
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 24/09/2021

Recognition of deducted items in calculation of own funds requirements for market risk

Are positions in own capital instruments - held for market making purposes and which have been deducted from own funds in accordance with Article 78 CRR in conjunction with Article 28(2) of Regulation (EU) No 241/2014 - still to be considered in the calculation of market risk requirements?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions
  • ID: 2020_5292
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 15/07/2022

Z 08.00 - Critical Services

What is the procedure that should be followed when the type of service is not in the predefined list available for selection, as one cannot add a new type?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans
  • ID: 2020_5293
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 31/03/2023

Definition of qualifying holding according to Article 4 (1) 36 CRR2

If a credit institution holds a participation below 10% in a company outside the financial sector - which according to the applicable accounting framework (IFRS) is accounted for by use of the equity method, due to the exercise of a significant influence according to IAS 28.5. - does this constitute a case of significant influence and therefore a qualifying holding according to Article 4(1)36 CRR? Can situations arise where a significant influence exists under accounting rules, but not according to the CRR definition?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5291
  • Topic: Own funds
  • Date of submission:

C76 – Updated LCR Calculation tool

The excel formulae in the updated LCR Calculation tool does not appear to be correct

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2020_5290
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Mount unattended contactless device on general goods vending machines

With the limits described in Articles 11 and 16 of the Regulatory Technical Standards on strong customer authentication and secure communication under Directive 2015/2366/EU (PSD2), could a vendor mount an unattended "contactless only" device without pinpad on a general goods vending machine?

  • 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: 2020_5288
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 11/03/2022

Callable deposits from financial institutions to be included in LCR with the entire outstanding

Are deposits from financial institutions considered callable and should therefore they be included in LCR for their entire outstanding amount, regardless their maturity?

  • 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: 2020_5287
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 11/02/2022

Treatment of non-withdrawable central bank reserves on C 66.

How should the non withdrawable part of the reserves placed with the Central bank be reported on the inflow section of the C66?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5286
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:

Validation rule v1251_m FINREP Taxonomy 2.8/2.9

Our question refers to EBA validationrule v1251_m which is, in our view, not always applicable. According to this rule F 05.01 [r010 c030] "Loans and advances from Credit institutions which are 'On demand [call] and short notice [current account]' must be equal to F 01.01 [r040 c010] 'Other demand deposits". The data point ‘On demand [call] and short notice [current account]’ in Template F 05.01 [r010 c030] includes ‘Loans and advances - On demand [call] and short notice [current account]’ from the accounting portfolio ‘Cash and cash balances at central banks’ as well as ‘Loans and advances - On demand (call and short notice (current account)’ from all other accounting portfolios ‘(..) other than Held for trading’. In our group Cash collaterals (paid) from OTC derivatives due to credit institutions are balanced as ‘Loans and advances. On demand (call and short notice (current account)’ in the accounting portfolio 'Financial assets at amortised cost' [F 01.01 r183 c010]. It is in our view not appropriate to report these collaterals as ‘Other demand deposits’ in F 01.01 [r040 c010 because they are no “Cash equivalents” according IAS 1.54(i) and because they are only payable when the contract is closed out. Therefore v1251_m is not a blocking validation rule and F 05.01 [r010 c030] can not (always) be equal to F 01.01. [r040 c010].

  • 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: 2020_5279
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Validation rules V_7329; V_7403 and V7409

Does validation rule V_7329; V_7403 and V7409 apply for columns that can (should) contain a negative amounts?

  • 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: 2020_5277
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

EBA validation rule v5313_m and v5315_m don`t work in Tax 2.9

EBA validation rule v5313_m and v5315_m don`t work in Tax 2.9

  • 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: 2020_5274
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 19/03/2021

Assets requiring stable funding

Where a national competent authority has instructed an institution to hold a pillar 2 liquidity add-on, should the pillar add-on amount be treated as an encumbered asset for the purpose of NSFR reporting?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5272
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 30/09/2022

Eligibility of convertible bonds for MREL

Would a convertible bond (Senior Non Preferred, Senior Preferred or Senior HoldCo) be deemed a structured note for the purpose of MREL eligible liabilities and therefore be excluded from MREL?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5265
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 30/03/2023

P2G ratio in template Z 03.00

Based on Annex II to Regulation (EU) 2018/1264, OCR and Pillar 2 Guidance (P2G) (row 0600 to row 0620 of template Z 03.00) is the sum of OCR ratio (r0500) for row 0600 and the P2G communicated by the competent authority. Should any relief measures due to the COVID-19 outbreak for P2G be taken into account or not?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans
  • ID: 2020_5266
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 31/03/2023

Safeguarding

Are payment institutions able to simultaneously adopt different safeguarding methods with respect to funds held?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5264
  • Topic: Authorisation and registration
  • Date of submission:
  • Published as final Q&A: 06/01/2023