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

ESG P3 - Templates 6, 7 and 8 - Scope of application as of 31.12.2023 and institutions’ exemption from EU taxonomy reporting until mandatory CSRD reporting as of 31.12.2024

Is the institution obliged to disclose Pillar III ESG templates 6, 7 and 8 as of 31.12.2023 despite its current exemption from EU taxonomy reporting until mandatory CSRD reporting as of 31.12.2024?

  • 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: 2023_6695
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 25/08/2023

Overcollateralisation and funded reserved accounts in C 14.01

Under framework v3.2, which column of template C 14.01 should contain the retained position of the overcollateralisation and funded reserve accounts shown in column 0254 of the COREP C 14.00?

  • 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: 2023_6694
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 21/04/2023

Reporting of securitisation positions when Article 244(1), point (b), CRR is applied

It is not clear how to report in C 13.01, C 14.00 and C 14.01 the securitisation positions held when Article 244(1)(b) CRR is applied.

  • 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: 2023_6693
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 21/04/2023

C43.00 (LR4) – Reporting of RWA for positions in CIUs

What value for RWA shall institutions report for positions in CIU considering that the look-through approach shall not be used for Leverage Ratio purposes?

  • 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: 2023_6692
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 22/09/2023

DPM 3.2 validation rule v11366_m for C84

This validation rule checks the following formula:   {C 84.00.z, r0120, c0030} = {C 84.00.x, r0010, c0020} * {C 84.00.w, r0220, c0040}   Our institution reports available funding for USD in datapoint in C 84.00.z, r0120, c0030}.   However our institution does not have any required stable funding for USD to be reported in datapoint {C 84.00.x, r0010, c0020}.  Therefore no USD NSFR ratio can be reported in datapoint {C 84.00.w, r0220, c0040}. Question is how to report these figures to comply to this validation rule in case no required funding and NSFR ratio for USD can be reported?

  • 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: 2023_6690
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 03/03/2023

SFTs exposure value on template C 48.02

What exposure value should be reported for a repurchase transaction on template C48.02 where the provided security is retained on the  balance sheet?

  • 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: 2023_6689
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as Rejected Q&A: 18/04/2023

Model implementation timeline given the received permission in relation to a material change

In accordance with Article 3(5) of Delegated Regulation 529/2014, “Where competent authorities have provided their permission in relation to a material extension or change, institutions shall calculate the own funds requirements based on the approved extension or change from the date specified in the new permission which shall replace the prior one. The non-implementation on the date specified in the new permission of an extension or change for which permission from competent authorities has been given, shall require a new permission from competent authorities which shall be applied for without undue delay”. It is not clear what does “the date specified in the new permission” refer to.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 529/2014 - RTS on materiality of extensions and changes in the advanced approaches (IRB and AMA)
  • ID: 2023_6688
  • Topic: Model validation
  • Date of submission:
  • Published as Rejected Q&A: 21/03/2023

Period to be covered by statistics pursuant to Article 32(4) of Commission Delegated Regulation (EU) 2018/389

Which period should the statistics to be published by ASPSPs under Article 32(4) of Commission Delegated Regulation (EU) 2018/389 cover in total?

  • 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: 2023_6687
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 29/09/2023

Other retail deposits subject to higher outflow rates

Do the retail customers of financial institutions like challenger banks or fintechs whose clients specifically use mobile apps to sign up, log in, top up, use the features like payments, open savings accounts, invest, and etc comply with “an internet-access only account” definition? Is there a difference between customers who hold virtual cards and cannot access their funds via ATMs and the ones that have physical cards and can do so?

  • 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: 2023_6686
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 16/10/2023

Residential property

Artcile 4 (75) presents the definitions for Residential property - “residential property” means a residence which is occupied by the owner or the lessee of the residence, including the right to inhabit an apartment in housing cooperatives located in Sweden; Question ID: 2015_2304 has a aswwer:  "For the avoidance of doubt, the exposure has to be secured by a mortgage on residential property which “is or shall be occupied or let by the owner”. This excludes situations where residential property “may” be built in the future (i.e. mortgages on land) but includes mortgages on building sites on which residential property will be built for the future owner of the property, or on residential property under construction, provided in both cases that there is certainty that the owner will occupy or let the property. In this sense, the 35% risk weight cannot be applied to exposures towards real estate developers. This treatment does only apply to exposures fully and completely secured by mortgages on residential property, and not where units were to be exploited commercially. " If real estate company owns houses/apartments/flats and this company leases them to natural persons (for living) does these houses/apartments are consideres as residential properties or commercial properties in Your view? Clear Yes and No answer is needed.  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6685
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 26/01/2023

Interpretation of the appropriate estimator for Credit Conversion Factors (CCF)

Is it possible to interpret the concept of “default weighted average from all observed defaults” as described for realised CCFs in article 182 of Regulation (EU) No 575/2013 as amended by Regulation (EU) 2019/876 as “the arithmetic average of the yearly averages”?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6684
  • Topic: Model validation
  • Date of submission:
  • Published as Rejected Q&A: 21/03/2023

Use simplified approach to calculate additional valuation adjustment (ava)

Is it permitted for an institution to use the simplified approach to calculate additional valuation adjustments (AVA) on the individual level, on condition that: i: the individual threshold ist not above the EUR 15 billion ii: this institut has fair valued positions only on the individual level (on consolidated level (group level) the institution has no fair valued position) iii. this institution is a part of a group breaching the EUR 15 billion threshold on a consolidated basis, but as mentioned before the institution has no contribution to the fair valued positions at consolidated basis

  • 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: 2023_6683
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 29/09/2023

C 27.00 - Identification of the counterparty (LE1) Report, column 040 -Residence of the counterparty

Reporting of the residence of the counterparty for a natural person. In order to report information on large exposures to natural persons the allocation in C27.00 Report column 040 -Residence of the counterparty should be done based on the country of residence or the country of nationality?

  • 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: 2023_6682
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 26/01/2023

ESG P3 - Template 7 Decision tree KPI GAR for Financial Corporation

In which row/group of rows from template 7 should be disclosed Financial Corporation located outside European Union (EU) and Financial Corporation located in EU but not subject to NFRD disclosures?

  • 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: 2023_6681
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 10/03/2023

Exposure to multilateral development banks

What are the criteria to be assigned a 0% risk weight by the EU under this regulation?  What is the process to apply to be assigned a 0% risk weight?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6680
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 24/02/2023

ESG P3 - Template 5 - NUTS codes for geographical areas outside EU

Does the regulation authorize to disclose any geographical area located outside European Union (EU) and UK?

  • 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: 2023_6679
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 10/03/2023

ESG P3 - Template 1- Attribution factor for financed emissions

In Template 1 of the final ITS, Commission Implementing Regulation (EU) 2022/2453 the GHG financed emissions should be reported in colimn i. With reference to the Annex 2 of the Regulation, institutions should  "taking into account their exposures [...] compared to total liabilities (accounting liabilities and shareholdes' equity)". This expression refers to an attributions factor that is similarly used in the GHG/PCAF-standard (EVIC, i.e. debt and equity). According to the expression, the attribution factor only applies for the "scope 3 emissions per sector" and is not explicitely named in column j for the "Of which Scope 3 financed emissions". Does the CRR-449a-attribution factor in column i and j apply for scope 1/2/3 of the counterparty? Does the attribution factor deviate from the GHG/PCAF-standard?

  • 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: 2023_6678
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 10/03/2023

ESG P3 - Template 1- Scope 3 financed emissions including scope 1 and 2 of the counterparty

In Template 1 of the final ITS (Commission Implementing Regulation (EU) 2022/2453) in column j the "Of which Scope 3 financed emissions" should be reported. Reading Annex 2 of the Regulation, "Institutions shall disclose their scope 3 emissions" where "their" refers to "institution" - this would be the scope-3-financed emissoions of the PCAF standard and therefor the total financed  emissions inclusing scope 1 /2 /3 of their (!) counterparties. Is is correct, that here only the counterparties scope-3-emissions should be reported?

  • 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: 2023_6677
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 10/03/2023

ESG P3 - Template 1- financed emissions to objects (PCAF-Standard) instead of counterparties

Regarding template 1 (ITS Commission Implementing Regulation (EU) 2022/2453) the "GHG financed emissions (scope 1, scope 2 and scope 3 emissions of the counterparty)" [see Annex 1] have to be reported. With respect to Annex 2 of the Regulation, the Reporting Standard of the Financial Industry (PCAF) is referenced (page 13), that is related to the institutions ("their") scope 3 emissions. Therefore, regarding projekt/object finance, we are not clear if the financed emissions of the specified object or the counterparty should be reported. E.g., if a bank finances/leases a car of/to a counterparty, should the scope 1/2/3 emissions of the counterparty (e.g. the company that buy the car that is partially financed by the bank)  be reported or the emissions of the car? So forth, should the attribution factor for the company or the attribution factor for the car (loan) be used?

  • 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: 2023_6676
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 10/03/2023