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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

Unrated short term claim/exposure

As per CRR Article 120(para 3, subpara c), it states: "If there is a short-term assessment and such an assessment determines a less favourable risk weight than the use of the general preferential treatment for short-term exposures, as specified in paragraph 2, then the general preferential treatment for short-term exposures shall not be used and all unrated short-term claims shall be assigned the same risk weight as that applied by the specific short-term assessment." Question: What is meant by unrated short-term claims as per this paragraph? If there is a general issuer rating available, will the exposures with residual maturity of less than 3 months be classed as Unrated and not eligible for preferential risk weight treatment as per CRR Article 120 (2)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2024_7111
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/07/2024

Risk weight for Exposures in default

What risk weight should be applied to in default exposures, under the standardised approach for credit risk? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7110
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/07/2024

Revocation of ASPSP's Exemption from the Contingency Mechanism due to Prolonged Service Disruption

In a scenario where an incident lasting more than two consecutive weeks preventing Payment Service Users (PSUs) from initiating their payments through a dedicated interface, considering that the Account Servicing Payment Service Provider (ASPSP) has an exemption from the contingency mechanism under Regulation (EU) 2018/389, and the National Competent Authority (NCA) has been notified about the incident: Should the National Competent Authority (NCA) revoke the ASPSP's exemption from the contingency mechanism?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2018/07 - Guidelines on the exemption from the contingency mechanism under Regulation (EU) 2018/389
  • ID: 2024_7103
  • Topic: Other topics
  • Date of submission:

Template 3: Banking book - Indicators of potential climate change transition risk: Alignment metrics

Is it allowed to use another scenario than those prescribed by the IEA, as long as it is compatible with 1.5C trajectory and clearly documented in the narratives?

  • 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: 2024_7102
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 28/06/2024

validation rules v16059_s and v16069_s for Template 3 are not aligned with above referenced article / paragraph in the ITS

We believe the validation rules are incorrect as they prescribe that the value should always be equal to or larger than zero, which is not always the case when applying the fixed formula for calculating the distance from the IEA Net Zero benchmark.

  • 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: 2024_7100
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 05/07/2024

Loan commitments, financial guarantees and other commitments received in F 9.2

Could you please more precisely clarify what should be presented as “Loan commitments, financial guarantees and other commitments received” in F 9.2?

  • 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: 2024_7099
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:

Misalignment between scope of reportable exposures against public authorities in template 7 ( CRR) and template 1 ( EU Taxonomy - acc to 2021/2178)

Should rows 280, 290 and 300 from Template 7 under ESG Disclosure only be limited to "Loans and advances" or should the scope of the rows be extended by including also debt security exposures (or other categories of exposures) in order to align with  Annex V from European Commission published on 27.6.2023 , updating Section 1.2.1.4 from 2021/2178 ?

  • 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: 2024_7097
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 28/06/2024

Maximum amount of the collateral or guarantee that can be considered in F 13.01 and F 18.00

Could you please more precisely clarify what should be used for “Maximum amount of the collateral or guarantee that can be considered”? Primarily use Market value of collateral as it is prescribed in ESRB Recommendation? or  Each Institute can have individual approach, where Internal collateral value (Market value of the assets reduced by a certain percentage => the “haircut”) also can be primarily used?

  • 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: 2024_7095
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 14/06/2024

Clarification needed in dedicated Interfaces supervision

We seek clarification and insights into how competent authorities shall fulfill their responsibilities in line with Recital 23 and Article 32.2 of the Commission Delegated Regulation (EU) 2018/389, specifically regarding the supervision of payment initiation service's dedicated interfaces to ensure effective oversight and monitoring.

  • 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: 2024_7093
  • Topic: Other topics
  • Date of submission:
  • Published as Rejected Q&A: 30/07/2024

Article 444f in CRR and ITS on public disclosures are not consistent with the mapping tool for the key metric LCR in KM1

It is clear in article 447f in CRR and in the ITS on public disclosures by institutions under Part Eight of Regulation (EU) N0 575/2013 (annex II) that average LCR should be reported in KM1 (as well as average of liquidity buffer, outflows and inflows). However, in the mapping tool the references to the LCR numbers in KM1 are to LCR numbers in templates C72, C73, C74 and C76, which are the templates where the regular LCR is reported.  The weighted average numbers for LCR are found in template LIQ1. So what is correct and what should be reported in KM1?

  • 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: 2024_7092
  • Topic: Transparency and Pillar 3
  • Date of submission:

Legal persons to whom the requirement to comply with reporting requirements under Article 54 of the IFR on a consolidated basis applies.

In case Article 7(1) of the IFR applies, does the requirement to comply with the reporting requirements under Article 54 of the IFR rest exclusively on either a Union parent investment firm, Union parent investment holding company or Union parent mixed financial holding company?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/2284 - ITS on Reporting
  • ID: 2024_7091
  • Topic: K-factor requirements
  • Date of submission:

Specification and operationalisation of the phrase "at all times"

How is the wording in Article 92 (1) CRR to be understood with regard to compliance with own funds requirements “at all times” in terms of verifiability?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7086
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 05/06/2024

List of IEA Sectors in Column a vs List of IEA Sectors in the EBA3.3 Annotated Table Layout for ESG

Based on the Excel version of Template 3 (Annex XXXIX), there are 8 sectors explicitly listed in column a (Sector / IEA Sector): Power Fossil fuel combustion Automative Aviation Maritime transport Cement, clinker and lime production Iron and steel, coke, and metal ore production Chemicals And referring to the ITS Annex XL - Instructions for disclosure of ESG risks - Paragraph 19(a), it also mentions that there are 8 mandatory minimum set of sectors: 19. Institutions shall disclose in this template: a. Columns a and b: these columns include the sectors (IEA sectors in column a) under which rows 1-8 lists the mandatory minimum set of sectors, and ..... However, in the "Annotated Table Layout 330-P1-ESG 3.3.xlsx" and in the data dictionary / DPM, downloaded from EBA's website, there are only 7 values mentioned for the IEA sector -  The <Key value> (combination of all <Key value> columns when more than one) must uniquely specify each row. Value restricted to subset [CT55]: (CT:x83) Carbon intensive firms (CT:x84) 1. Power (CT:x85) 2. Fossil fuel combustion (CT:x86) 3. Automotive (CT:x87) 4. Aviation (CT:x88) 5. Maritime transport (CT:x89) 6. Cement, clinker and lime production (CT:x90) 7. Iron and steel, coke, and metal ore production   The IEA Sector named "Chemicals" is not included in the EBA 3.3 list of values. Will either the Excel version and ITS be updated to remove "Chemicals" from the list of mandatory minimum set of sectors or the "Annotated Table Layout for ESG" be updated to include "Chemicals"?  

  • 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: 2024_7085
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 26/07/2024

Template 5 - Reporting of gross carrying amount of exposures sensitive to chronic, acute, chronic and acute climate change events

In Template 5, should the gross carrying amount of exposures in column j (of which exposures sensitive to impact from both from chronic and acute climate change events) be reported also in column h (Of which exposures sensitive to impact from chronic climate change events) and column i (Of which exposures sensitive to impact from acute climate change events) or is the gross carrying amount of exposures reported in these 3 columns mutually exclusive?  

  • 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: 2024_7080
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 26/07/2024

Interpretation of ‘ The degree of correlation between the value of the assets relied upon for protection and the credit quality of the obligor shall not be too high.’

In Article 194, Quote Institutions may recognise funded credit protection in the calculation of the effect of credit risk mitigation only where the lending institution has the right to liquidate or retain, in a timely manner, the assets from which the protection derives in the event of the default, insolvency or bankruptcy — or other credit event set out in the transaction documentation — of the obligor and, where applicable, of the custodian holding the collateral. The degree of correlation between the value of the assets relied upon for protection and the credit quality of the obligor shall not be too high. Unquote My question is about the aforementioned correlation. If a obligor’s major asset is a very valuable mine asset, and the mine asset is collateralized by a bank as security for a loan, is it eligible for the bank to consider the value of the mine asset for calculating the ‘risk-weighted asset’? The value of the mine asset is valued by independent & renowned evalution agency and it meets with all other regulatory requirements for eligible collateral.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/09 - Guidelines on corrections to modified duration for debt instruments under Article 340(3) CRR
  • ID: 2024_7079
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/06/2024

Trading desk requirements for Standardized approach perimeter

Could you please confirm whether all desks in the prudential perimeter, independently from the internal model or standardized approach, should respect the requirements for trading desks reported in Article 104b and other provisions for trading desks?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7076
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 28/05/2024

Trading and Banking book positions within a Trading desk

Could an A-IMA eligible Trading desk have trading and banking book positions segregated in different portfolios within the same desk, given that non-trading book positions are carve-out from A-IMA calculations?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7075
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 28/05/2024

Classification of Repo Transaction

How can internal repo transactions be managed in the calculation of the regulatory capital requirement in the A-IMA trading desk? Can these transactions be carved out from the scope of regulatory capital requirement of the A-IMA trading desk? Does the regulation prescribe that the funding in repos should be allocated to the trading/banking book accordingly to the funding strategy purpose? (if the funding is for banking book positions, the repos are non-trading instruments, if the funding is for trading book strategy the repos are trading book instruments). Is it possible to have different prudential classification of internal repos and external repo transactions on the market?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7074
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 28/05/2024

Treatment of two-leg derivatives with respect to rate type and currency

What is the expected representation for two-legs derivatives in the templates "BREAKDOWN OF SENSITIVITY ESTIMATES (J 02.00, J 03.00 and J 04.00)" and REPRICING CASH FLOWS (J 05.00, J 06.00 and J 07.00)?

  • 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: 2024_7073
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:

Reporting Requirements per type of institution

Are small and non-complex/other institutions required to use the simplified set of templates, or can they use the Large format if they already have to produce it, for example, for their holding/parent company?

  • 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: 2024_7072
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 28/05/2024