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List of Q&A's

Validation rules taxonomy V4.0 C_17.01

Validation rule v23510_h incorrect

  • 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_7573
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Calculation rule

Please precise calculation rules for : number of transactions on proprietary accounts (column 0100) number of transactions on clients accounts (column 0110) Cumulated notional amount  (column 0140)

  • 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: 2025_7572
  • Topic: Resolution plans
  • Date of submission:
  • Published as Rejected Q&A: 27/11/2025

Provide a detailed definition of the 'operator' of the FMI.

Please provide a detailed definition of the 'operator' of the FMI, and some examples.

  • 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: 2025_7570
  • Topic: Resolution plans
  • Date of submission:
  • Published as Rejected Q&A: 27/11/2025

Finrep validation between F09.01.1 and F18.00 other commitments given

If we have undrawn credit facilities that based on CRR Annex I are reported under Other commitments given in F18.00 r0480 c0010, but they do not meet any of the conditions described in Annex V Part 2.105 (a-c) to be reported in F09.01.1, we cannot report them on F09.01.1 but in F18.00 only.  Validation errors  v2795_m: [F 18.00.e, F 09.01.1] {F 18.00.e, r0480, c0010} = {F 09.01, r0170, c0010} + xsum({F 09.01.1, (r0170, c0010, c0020, c0030, c0035, c0100)}) and v2797_m: [F 18.00.e, F 09.01.1] {F 18.00.e, r0500, c0010} = {F 09.01, r0200, c0010} + xsum({F 09.01.1, (r0200, c0010, c0020, c0030, c0035, c0100)})  require that Other commitments given match in both these tables. What if the conditions mentioned in Annex V Part2.105 are not met for the other commitments given in F18.00?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7569
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 16/10/2025

Disclosure on more periods in one template

In some reports of the Pillar 3 reporting obligations some cells are specifically asking for the amount of the previous periods to be declared : For instance  : Report K6000 - EU OV1 – Overview of total risk exposure amounts : Column 0020 T-1 On those reports we are having some different interpreations with some of our clients regarding what is expected to be fed in column T-1. Some of our client think that column T-1 should always refer to the end of the previous financial year, meaning that when reporting figures for Q2/Q3/Q4 2025 the figures reported in column 0020 should of report K6000 should remain unchanged and should always report the data of Q4/2024.   In our intepretation of the ITS, we understand that in case : The Entity has to report a table on a quarterly frequency in this case the T-1 figures should always reflect the figures of the previous quarter, so for closing date Q2/2025 column 020 of K6000 should be populated with figures coming from Q1 2025, so for closing date Q3/2025 column 020 of K6000 should be populated with figures coming from Q2 2025, so for closing date Q4/2025 column 020 of K6000 should be populated with figures coming from Q3 2025, The Entity has to report a table on a Yearly frequency in this case the T-1 figures should always reflect the figures of the previous year, so for closing date Q4/2025 column 020 of K6000 should be populated with figures coming from Q4 2024 Can you please indicate the correct expectation of EBA ?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 650/2014 - ITS on disclosure by competent authorities
  • ID: 2025_7567
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 26/09/2025

Is the EBA mapping file for Pillar 3 template EU CMS1 correct?

Is the EBA mapping file for Pillar 3 template EU CMS1 correct disallowing amounts to be reported on column a/row 8 and requiring items that could relate to IRB approach to be reported in column b (SA)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR
  • ID: 2025_7563
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2025

COREP C22.00 reporting of positions in the reporting currency

Can EBA provide some examples of cases where positions in the reporting currency contribute to the calculation of the capital requirements according to Article 354 CRR?

  • 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_7562
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 12/11/2025

C_ 08.01.a - qx 2068 – “Retail exposures - Secured by residential real estate”

Should the retail exposures secured by residential real estate to a natural person and the retail exposures secured by residential real estate to an SME both be assigned to the exposure class of “Retail exposures secured by residential real estate” in C_08.01.a qx 2068?

  • 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_7561
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

C02 Own Funds Requirements CA2 - Row 0050 - inconsistent requirements for securitisation positions

The ITS for row 0050 states: "CR SA and SEC SA templates at the level of total exposures", information that hasn't changed between DPM 3.2 and DPM 4.0. The validation rule v0205_m with {tC_02.00.a, default: 0, interval: true}: {r0040} = {r0050} + {r0240} + {r0460} + {r0470} is inactive starting with 3/10/2025 and so far the securitisation positions reported on row0470 column 0010 were considered in the calculation of the row0040. Considering the ITS, are the securitisation positions from row 0470 requested on row0050 in regards of each column 0010 TREA and 0020 S-TREA?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7559
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2025

Onboarding capacity - Number of applications from new customers over 1 working day

If the bank has a central team managing all account openings within the group, with colleagues assigned to a specific Member State. E.g. two colleagues are dedicated to opening accounts in Luxembourg, how should we clarify the “Onboarding Capacity”, which is defined as the highest number of applications where the institution has validated the request for a bank service? We seek guidance on which of the following approaches would be most relevant: Real statistics-based calculation: if the average daily number of new accounts opened in Luxembourg is 1 (handled by 2 colleagues in the central team), should the onboarding capacity be reported as 1? And if it takes 15 days to onboard new client (handled by 1 colleague or 2 colleagues in the central team)  in Luxembourg then should we report 0 or 0.1 (1 application /10 days)? Full Central Team Capacity (Single Country): if the entire central team were assigned exclusively to Luxembourg, the average daily onboarding capacity could increase to 5. Should this theoretical highest number of 5 be considered for Luxembourg ? Kindly note that in the capacity of the capacity for every other country would be zero as a consequence. How then to report for the remaining countries? Full Central Team + Project Support (Single Country): If the central team had the additional project support (e.g. temporary resources), the average daily capacity for Luxembourg could reach a higher level, e.g. 50. Should such scenarios be considered for “Onboarding Capacity”?

  • 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: 2025_7556
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 27/11/2025

Validation rules v23509_h and v23510_h appear incorrect

Are validation rules v23509_h and v23510_h 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: 2025_7555
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Inconsistency between Annotated table CODIS Pillar III and Mapping_tool_including_step_2_tc (incl equity) + Rev 4.1 review_tc

How should we interpret and implement the differences between the Annotated table and the Mapping Tool referring to template CCR4 - K04.00?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR
  • ID: 2025_7554
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2025

v23509_h and v23510_h

Are the validation rules v23509_h and v23510_h correct when reading the reporting instruction of the ITS. In our view the reporting instruction of the ITS is not clear enough.

  • 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_7552
  • Topic: Supervisory reporting
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

C17.01 - v23508_h - Sum of number of events by Basel Business Line

Is the aggregation logic assumed by the control v23508_h applicable in this context?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7551
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

C17.01 - v23507_h - Sum of number events by Basel Business Line

Is the aggregation logic assumed by the control v23507_h is not applicable in this context.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7550
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

C07.00 - v23338_m - RW of 70% empty

The EBA Validation Rule v23338_m applicable to C07.00 COREP template states that the line 210 that concerns the RW of 70% must be empty. Should this control should be applicable?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7549
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

C06.02 - v23688_s - Non negative control

The control indicates that the following columns have to be positive :   c0360 = consolidated own funds   c0370 = of which : common equity Tier 1   c0390 = oh which: contribution to consolidated result Should this control be applicable?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7548
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Validation rule v23688_s requiring only non-negative amounts appears incorrect

Is validation rule v23688_s incorrect? 

  • 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_7547
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Pillar 3 Disclosure: Template EU CQ1: Credit quality of forborne exposures (Col e & f; R090 Loan commitments given ) - Clarification on Mapping Logic

According to the EBA mapping: (Col e & f ; R0090) for row “Loan commitments given” under impairment section are mapped to template F19, which is presented as a positive value in CR1. However, our understanding is that impairment values should be disclose as negative figures in CQ1. Please confirm whether this interpretation is correct. 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7546
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 21/08/2025