Search for Q&As

Enquirers can use various factors to search for a Q&A:

  • These include searching by the Q&A ID; legal reference, date submitted, technical standard / guideline, or by keyword if known.
  • Searches can be extended to more than one legal act, topic, technical standard or guidelines by making multiple selections (i.e. pressing 'Ctrl' on your keyboard, and selecting the relevant ones from the drop-down lists by left mouse-click).

Disclaimer:

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.

Final Q&As Q&As under review Rejected Q&As Archived Q&As All Q&As

List of Q&A's

CRE loans versus Loans collateralised by commercial immovable

The question concerns the classification of commercial real estate (CRE) loans and loans collateralised by CRE in template F 18.02 of FINREP. It is not clear whether the two loan categories are mutually exclusive or whether it is possible that a loan can be classified both as a CRE loan and as a loan collateralised by CRE.

  • 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
  • ID: 2022_6552
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 31/03/2023

Identification of counterparty

The treatment of client exposures to a CCP via a clearing member is described in art 305 and consists of 1/ application of art 305 paragraph 1 (when the conditions in paragraph 2 are not met) = use of counterpart credit risk section 1 to 8 for the CCP-related transactions with the clearing member 2/ application of art 305 paragraph 2 (and subject to paragraph 3) = use of art 306 for the trade exposures with the CCP Can it be clarrified which party should be treated as the counterparty in sush a transaction (the clearing member or the CCP) under Corep? Can it in addition be clarrified whether the same counterparty as in Corep should be used under Finrep?    

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6551
  • Topic: Market infrastructures
  • Date of submission:
  • Published as Rejected Q&A: 28/03/2023

Promotional loans that constitute claims on central governments, regional governments, local authorities or public sector entities

As per article 429a (1), paragraph (d) of CRR, only claims on central governments, regional governments, local authorities or public sector entities in relation to public sector investments and promotional loans are exempt from Leverage ratio exposure where the institution is a public development credit institution, the exposures arising from assets that constitute claims on central governments, regional governments, local authorities or public sector entities in relation to public sector investments and promotional loans. In C40 report, ITS mentions that this part of the reporting collects data on an alternative treatment of derivatives, SFTs, off-balance sheet items, exempted public sector investments and exempted exposures to promotional loans. In C40 report also only exempted exposures to promotional loans are to be reported. That is claims on central governments, regional governments, local authorities or public sector entities only are to be reported in C40 report also. Row 0350 of C40 report requirement Promotional loans - Claims on non-financial corporations - Accounting balance sheet value Where the institution is a public development credit institution, the accounting balance sheet value under the applicable accounting framework of assets that constitute claims on non-financial corporations in relation to promotional loans Row 0360 of C40 report requirement Promotional loans - Claims on households - Accounting balance sheet value Where the institution is a public development credit institution, the accounting balance sheet value under the applicable accounting framework of assets that constitute claims on households in relation to promotional loans  As the only exposures to promotional exempt are to be reported in C40 also. However these two rows 0350 and 0360 of C40 report requirements are not in cosistence with the article 429a (1) (d) and (e) also. Please clarify.

  • 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
  • ID: 2022_6550
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as Rejected Q&A: 18/04/2023

v5839_m vs Q&A 5434

When will the validation rule v5839_m reflect changes recommended in Q&A 5434 of the Single Rulebook Q&As?

  • 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
  • ID: 2022_6549
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2022

Securitised derecognised assets

Template C 14.00 (SEC DETAILS), column 0210, requires reporting of information on securitised exposures including associated provisions. The memorandum item on the standardised calculation in C 14.01 (SEC DETAILS APPROACH), column 0448 also requires provisions on underlying asset as an input. What provisions should be used when the securitised exposures are also derecognised by the reporting entity from an accounting perspective?

  • 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
  • ID: 2022_6548
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 13/10/2023

ITS ESG P3 - Non-financial risks and value chain

1. Should entities report their own non-financial risks arising from its own operations, or only the non-financial risks related to the operations of its counterparts and customers? 2. If “counterparts” includes the latter then; what is the definition of a “counterpart” ? Does it include the third party value chain e.g. suppliers and outsourcing agreements?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2022_6544
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 17/02/2023

v6303_m not passed due to market conditions (C 24.00)

Because of the evolutions of the rates, the ratio SVaR/HVaR has dropped such that the SVaR is below the HVaR. In coordination with the local supervisor, we compensate this RWEA underestimation by applying a self-imposed RWA add-on through the application of Article 3 CRR. However, when we report the information of template C 24.00, the validation rule v6303_m blocks the submission because it enforces the following rule v6303_m: [C 24.00 (r0010)] {c0060} >= {c0040} We request de-activation of this rule so that our report can be submitted.

  • 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: 2022_6543
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2022

Template 5: Banking book - Climate change physical risk: Exposures subject to physical risks

What is the relation between row 1-9 and 10-12? Are rows 10-12 based on the sectors mentioned in 1-9 only, or based on all sectors (including the ones not mentioned in 1-9)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2022_6541
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 25/11/2022

Possible error in v8116_m

Is the following rule v8116_m: [F18.01 (c0020)] {r0050} <= {r0060} correct?

  • 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
  • ID: 2022_6542
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 31/03/2023

Deposit broker

If the original depositor is a PIC, could be classified as a deposit broker?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6540
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 21/12/2022

Meaning of "established in the Union"

Article 18 of the Securitisation Regulation requires that “The originator, sponsor and SSPE involved in a securitisation considered STS shall be established in the Union”: Would this provision deemed to be fulfilled in the case of originators, sponsors and SSPEs established in an EEA country? Would it be deemed to be fulfilled in the case of an originator which is an EU branch of a subsidiary  established in an EEA State pertaining to a banking group established in the EU?

  • Legal act: Regulation (EU) No 2017/2402 (SecReg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6539
  • Topic: Simple Transparent and Standardised securitisation
  • Date of submission:

Questions on final draft implementing technical standards (ITS) on Pillar 3 disclosures on Environmental, Social and Governance (ESG) risks - template 10

Should the timelines of template 10 align with the EU Taxonomy timelines? And is it allowed to report exposures in template 10 that later will be considered EU Taxonomy aligned?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6538
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 11/11/2022

Template 5 - Definition of time horizons

With regards to the Final draft implementing technical standards (ITS) on prudential disclosures on ESG risks in accordance with Article 449a CRR, specifically regarding Template 5 of related Annex XXXIX, could you specify 'time horizon'?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2022_6537
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 25/11/2022

ITS ESG P3 - Template 4 - Top 20 emitting companies aggregation

Should reported exposures to top 20 most emitting companies be reported at a group or individual company level?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2022_6536
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 17/02/2023

Template 10: other climate change mitigating actions - Columns d and e

Could you specify which kind of answers are expected under 'type of risk mitigated' (column d and e)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2022_6533
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 25/11/2022

Template 2 - Row 5 subset

Template 2 of Annex XXXIX to the Final draft implementing technical standards on prudential disclosures on ESG risks in accordance with 449a CRR – Is row 5 a sub-set of rows 2/3/4?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2022_6532
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 25/11/2022

C 34.08 – Reporting of received collateral

Regarding the columns pertaining to the ‘Fair value of collateral received’ of template C 34.08 of Annex 1 of Regulation (EU) 2021/451 (i.e. columns 0010 – 0040 and 0090 – 0130), both the general guidance for the template (paragraph 131) along with the specific guidance for these columns provided in Annex II state that the institution shall report the fair values of received collateral that is used in CCR exposures. Is the correct interpretation of the term ‘used in CCR exposures’, that only the portion of received collateral that is actually used to offset CCR exposures should be reported in C 34.08, and not the full original fair value of collateral received relating to CCR exposures?

  • 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
  • ID: 2022_6530
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 21/04/2023