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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

Treatment of CIUs in internal model for market risk – own funds requirement (add-on)

Has the add-on for specific risk for CIUs according to Art. 364 (2) lit. a) in any case to be calculated for CIUs which are included in an internal model for market risk using a different approach than those described in Art. 350 (1) or 350 (2) (e.g. based on the liquid price of the CIU)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4380
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 21/01/2022

Treatment of CIUs in internal model for market risk – possible restrictions

Is the use of internal models to compute own funds requirement for market risk of positions in CIUs restricted to either of the conditions referred to in paragraphs (1) and (2) of Article 350?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4378
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 04/12/2020

Treatment of CIUs in internal model for market risk – partial use

What are the conditions to include a CIU in an internal model with regard to model approval and risk categories for partial use institutions?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4377
  • Topic: Market risk
  • Date of submission:

Certfication in relation to a Technical Service Provider (TSP)

When performing the role of a Technical Service Provider (TSP) is the TSP required to update the certificate received from the Third Party Payment Service Providers (TPP) (to demonstrate our involvement) to enable the Account Servicing Payment Service Provider (ASPSP) to authorise the certificate and provide the appropriate requested data back through to the TPP and establish the session? Is this same certificate required for every type of transaction request and must it be real time checked by the ASPSP and how does this impact our role as a TSP?Also, by introducing a TSP between a TPP and an ASPSP is the concept of private keys and the transport layer broken, due to the introduction of a TSP between the TPP and the ASPSP? Finally, are there limits to the number of roles involved in the chain in terms of the certification or do we just need to be able to demonstrate the link back to the point of origin for the certificate (the TPP)?

  • 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: 2018_4375
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 24/05/2019

Reverse repos (Reverse Repurchase Agreements) in AE-Assets Encumbrance

RE 680/2014, Annex XVI, § 2.1.1.14 (b) deals with Repos / Matching (or Reverse) Repos in the AE-Assets Encumbrance reporting. Questions : 1)where must be reported in AE-ASS (F32.01) and by impact in AE-ADV1 (F36.01) the cash received by the reporting institution from its Reverse Repos ? because it should be registered among the Encumbered Assets whereas the (iv), taken over below in Background section doesn’t evoke the treatment for the carrying amount, contrary of Repos in the paragraph (iii). 2) the paragraph (iv) of the mentioned article indicates that the fair value of the collateral of reverse repurchase is reported including AE-SOU (F32.04), r050, c030 and 040 : is c030 provided for Reverse Repos and c040 for Reverse Repos regiven in Repos ?

  • 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: 2018_4372
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Categories of Registration

Is it a requirement that all EU countries include the categories the institution is approved for within their respective registers i.e. in their publicly available data? Also are these categories available in a consistent and standard format across the EU such that anyone inquiring about a firm in more than one country has an easily recognisable and usable response

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/09 - Guidelines on authorisation and registration under PSD2
  • ID: 2018_4371
  • Topic: Authorisation and registration
  • Date of submission:
  • Published as final Q&A: 19/06/2020

Originator obligations

What are the obligations of an originator who purchases third party's exposures and subsequently securitises them, in order to meet the requirements set out in Article 9 of the Securitisation Regulation?

  • Legal act: Regulation (EU) No 2017/2402 (SecReg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4368
  • Topic: Provisions applicable to all securitisations
  • Date of submission:
  • Published as final Q&A: 13/09/2019

Showing a password after it has been masked

Article 22, 2(a) states that "personalised security credentials are masked when displayed and are not readable in their full extent when input by the payment service user during the authentication". Is it ok to offer the user a "show password"-button, so the user can verify that correct password has been entered, before fulfilling an authentication?

  • 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: 2018_4366
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 08/02/2019

Exposure amount for unfunded default fund contribution (UDFC)

How should the exposure value of UDFC from an own fund requirement and from a leverage ratio perspective be calculated?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4364
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Application of the exemption related to a trusted beneficiary

Has the exemption related to a trusted beneficiary to be applied on an account basis or rather to a list of accounts included in an online banking agreement ? Whose list has to be considered in case of a power of attorney where the initiator is not the account owner ? What happens in case of a shared account where each one holds his own trusted beneficiary lists ?

  • 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: 2018_4360
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 08/03/2019

Does SCA apply to electronically processed SEPA Direct Debits ?

When processing SEPA Direct Debits electronically (assuming that the Direct Debit mandate has been signed digitally), does SCA apply to transactions? If not, what is the legal basis for this exemption?

  • 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: 2018_4359
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 22/02/2019

Validation rule v0853_m - Framework release 2.8

In tables F10.00 and F11.01 should the notional amount of derivatives be reported if the fair value is equal to zero?

  • 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: 2018_4355
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Is a gradual reduction of the overdraft facility with a current account a forborne measure?

Should an exceeded overdraft facility, which is gradually reduced by the bank as stipulated in terms and conditions, be classified as forborne exposure even if the customer does not meet any criteria for default?

  • 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: 2018_4346
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 12/04/2019

Transactions to consider in the share of interbank loans and deposits in the European Union

Could you confirm the share of interbank loans and deposits in the European Union aims at reflecting the share of interbank transactions of an institution with other institutions established in the European Union?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/63 - DR on ex ante contributions to resolution financing arrangements
  • ID: 2018_4344
  • Topic: Resolution financing arrangements
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Chip and Signature cards and their inclusion in the remit of RTS Article 11

Is cardholder signature a strong method of authentication when transacting with card present?If so, is there a requirement to ensure that on Chip and Signature cards we step up to signature from contactless after 5 contactless /cumulative value of 150 euros?If a signature is not considered to be strong customer authentication (SCA), are chip and signature cards exempt from SCA requirements under Article 11 of the RTS on strong customer authentication and secure communication?

  • 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: 2018_4342
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 09/04/2021

90 Day Access via Direct Access

Should any solution which involves direct access, whether as a strategic solution to PSD2, or in relation to the obligation to provide a fallback interface, ensure that Account Information Service Providers (AISPs) can access the interface in the same manner as the dedicated interface, specifically on an ongoing basis and for a maximum of 90 days once the customer has provided consent and authenticated using strong customer authentication (SCA)?

  • 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: 2018_4339
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Trusted Beneficiaries

Article 13 of the RTS on strong customer authentication (SCA) and secure communication does not seem to restrict the use of trusted beneficiaries beside the fact that the payee must be in the list of trusted beneficiaries when initiating the payment transaction. Is it correct to conclude from this that the usage of trusted beneficiaries is not further restricted and can, therefore, also be implemented as a generic beneficiary approval step prior to every initiation of a payment transaction?

  • 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: 2018_4338
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 09/04/2021

FINREP Locom valued debt instruments: Reporting of "Accumulated negative value adjustments on LOCOM assets - credit risk induced"

Could it be that the following validation rules 5319_m until v5331_m are not correct for LOCOM valuated debt instruments. Should  "Accumulated negative value adjustments on LOCOM assets - credit risk induced"  be reported under accumalated impairment and not under "Accumulated negative changes in fair value due to credit risk on non-performing exposures"?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4336
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Finrep Solo GAAP: The following validation rules v5476_m until v5489_m are missing the column"Accumulated negative value adjustments on LOCOM assets - credit risk induced"

Dear Could it be that the the column "Accumulated negative value adjustments on LOCOM assets - credit risk induced" is missing in the validation rules from v5476_m until v5489_m?

  • 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: 2018_4335
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Mark-to-Market Method: remaining maturity for early-termination clauses (ETC)

For the purpose of determining the percentage applicable under the Mark-to-Market Method according to Article 274(2) or (3) CRR, how should the residual maturity be determined for contracts with an early-termination clause?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4329
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 07/05/2021