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List of Q&A's

FINREP Identical Cells 5458783, 5458788, 5459395, 5460187

Could the EBA confirm whether these identical cell checks are correct? If not, should they be updated to align with the previous logic (v8610_i, v8611_i, v10006_i, v10007_i) to ensure consistency between templates and definitions?Please clarify the intended scope of collateral reporting in these templates and whether the current rules will be revised.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7660
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 23/12/2025

FINREP Validation rules v23845_h, v23846_h, v23847_h

Could the EBA clarify the rationale for excluding rows 0015, 0185, and 0365 from the new validation rules for template F 12.01.a?This change creates inconsistencies with cross-template validation rules such as: v6030_m: {tF_12.01.a, r0010, c0100} - {tF_12.01.a, r0015, c0100} = {tF_04.03.1, r0180, c0050} + {tF_04.04.1, r0140, c0050} v6033_m: {tF_12.01.a, r0180, c0100} - {tF_12.01.a, r0185, c0100} = {tF_04.03.1, r0180, c0060} + {tF_04.04.1, r0140, c0060} v6036_m: {tF_12.01.a, r0360, c0100} - {tF_12.01.a, r0365, c0100} = {tF_04.03.1, r0180, c0070} + {tF_04.04.1, r0140, c0070} These rules assume that rows 0010, 0180, and 0360 include “Cash balances at central banks and other demand deposits.” Additionally, the items “of which: collectively measured allowances” and “of which: individually measured allowances” will no longer consider these balances because the related rules (v5054_m, v5055_m, v5056_m) reference rows 0010, 0180, and 0360 only. Could the EBA confirm whether this exclusion is intentional and, if so, provide guidance on how to reconcile these templates and validation rules?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7659
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 23/12/2025

Controls v4968_m, v5024_m, v5372_m, v5373_m and v5376_m

Please note that controls v4968_m, v5024_m, v5372_m, v5373_m and v5376_m should have the condition "eba_qAS:qx2004" instead of "eba_AS:x2" to comply with column 010 of row 010 of report F_00.01

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7655
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 23/12/2025

C_07.00 : columns 010 to 040 of line 210

I would like to point out that columns 010 to 040 of line 210 of report C_07.00 should have been ungreased in the EBA 4.2 taxonomy to be in accordance with the EBA's answer to question 2025_7348.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7654
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 23/12/2025

EBA publication of loss rates for Swiss residential and commercial property under CRR Articles 125 and 126.

Will the EBA publish loss rate data for Swiss residential and commercial property markets to enable institutions to apply preferential risk weights under Articles 125 and 126 CRR? If yes, what is the expected timeline?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7635
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

Clarification on the relationship between Margin of Conservatism (MoC) and rating/calibration philosophy (PIT vs TTC) under EBA Guidelines on PD and LGD estimation (EBA/GL/2017/16)

According to the EBA Guidelines on PD and LGD estimation (EBA/GL/2017/16), the Margin of Conservatism (MoC) aims to address uncertainty arising from data and methodological deficiencies, changes in underwriting standards or risk appetite, and general estimation error. The Guidelines describe the three MoC categories (A, B, C) and the principles for quantification, but they do not explicitly refer to any link between MoC and the chosen rating philosophy (Point-in-Time vs Through-the-Cycle) or calibration philosophy. Could you please clarify whether the regulator expects the MoC concept to be aligned with the institution’s PIT/TTC philosophy, or whether MoC is entirely independent of the rating/calibration philosophy?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/16 - Guidelines on PD estimation, LGD estimation and the treatment of defaulted exposures
  • ID: 2025_7634
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

Template 2 - EBA validation rules v89325_m and v89326_m

The formula linked to the following rule IDs: v89325_m and v89326_m appears to be incorrect

  • 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: 2025_7633
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 12/01/2026

Obligations in Equity exposures of Article 133 (1) (c) (i) CRR

Does the term “obligation” in Article 133 (1) (c) (i) CRR refer to the principal amount, or does it also refer to the interest payment solely? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7631
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

Netting of foreign exchange derivatives (as per Annex (II, a-e) of Reg. No 575/2013) in Net Stable Funding Ratio (NSFR)

What criterion should be adopted for the treatment of a foreign-exchange derivative contract included in a netting set between what reported in Article 428d(4) and in Article 428d(2) of CRR2?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7625
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 11/12/2025

Corporate exposures in C10.00 memorandum lines r0250 and r0260

In template C10.00, institutions that apply the IRB approach, shall break down IRB exposures by SA exposure class. This template includes the following 2 memorandum lines: r0250 Corporates - F-IRB  r0260 Corporates - A-IRB How should 'Corporates' be interpreted for these two memorandum lines? Does that relate to the volume reported on rows r0100 (Corporates - other) and r0120 (corporates - specialised lending) of template c10.00? The ITS does not clarify this. Therefore the question is whether the sum of rows r0250 and r0260 should reconcile with the sum of C10.00 rows r0100 and r0120? An alternative interpretation is that the SUM of rows r0250 and r0260 should reconcile with the sum of corporate exposures reported in the C08.01 IRB template. We feel that this alternative interpretation is not logical as it would repeat numbers already (separately) reported in C08.01 and separately identifiable, both whether it relates to 'corporates' and whether it relates to A-IRB and F-IRB is identifiable via the Z-axis. Therefore we feel that this interpretation will not add any added value. Could you please clarify to which 'Corporates' lines r0250 and r0260 refer?

  • 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_7624
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 27/11/2025

Pillar 3 Template EULR2 - LRCom: Leverage ratio common disclosure (Row 24) Instruction

Pillar 3 Template EULR2 - LRCom: Leverage ratio common disclosure (Row 24) Instruction In the current instruction for Row 24, it states: “Sum of amounts in rows 7, 13, 18, 22, and EU-22k of EU LR2 – LRCom.” However, based on the latest EBA mapping table/logic, the correct reference should be: LRCom (sum of rows 7, 13, 18, 22, EU-22m). This aligns with our understanding that the correct row is EU-22m, not EU-22k. Could EBA please update the instruction accordingly?

  • 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_7620
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 12/01/2026

v6332 - Negative FV changes os hedged intems (C 32.01)

In relation to Q&A 2022_6511 where a question was raised related to validation rule v6566_s. We believe validation rule v6332_m should be deactivated for row 120.

  • 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 (repealed)
  • ID: 2025_7619
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/11/2025

Liability category of margins received

Could you please clarify if margins received, part of a repo or derivative netting agreement can always, regardless of whether the netting results in a net liability or asset position, be considered r0120 - Secured liabilities, or should be allocated to other liability categories as defined in Resolution Plans report Z02? 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on the provision of information for the purpose of resolution plans
  • ID: 2025_7615
  • Topic: Resolution plans
  • Date of submission:
  • Published as Rejected Q&A: 27/11/2025

Finrep Validation Rules v4975_m and v6058_m6

The validation rules v4975_m and v6058_m appear to systematically fail when institutions hold loans measured at fair value through other comprehensive income (FVOCI). These rules seem not to reflect that fair value remeasurement adjustments on FVOCI loans are recognised directly in the balance sheet through equity. Could the EBA confirm whether these validation rules should exclude FVOCI instruments from their scope, or whether they will be revised to properly reflect valuation adjustments recognised in the balance sheet under IFRS 9?

  • 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_7611
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 11/12/2025

Reporting of debt securities issued but not yet paid up

What is the expected representation for a debt security issued but not yet paid up in the templates REPRICING CASH FLOWS (J05, J06 and J07)? Is the expected monetary inflow supposed to be reported and if so in which row?

  • 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 (repealed)
  • ID: 2025_7610
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:

Clarification request - CP Pillar 3 ESG - Template 2 covered bonds

We are reaching out regarding the Consultation Paper published by EBA on 22/05 concerning Pillar III ESG disclosures. Specifically, we would kindly request clarification about the additional line required in Template 2 related to covered bonds: "In addition, a breakdown for information on cover pool of covered bonds is requested in rows for the Total EU area and Total non-EU area (rows 1.1 and 6.1 respectively)."   As stated in the CP document: “Following Recital 55 of the CRR3, the EBA is asked to assess means to enhance the disclosures on ESG risks of cover pools of covered bonds and to consider whether information on the relevant exposures of the pools of loans underlying covered bonds issued by institutions, either directly or through the transfer of loans to a special purpose vehicle (SPV), should either be included in the revised ITS or in the regulatory and disclosure framework for covered bonds”   We would appreciate your guidance on the following points: • Should only the covered bonds issued by the institution reporting the template be considered? Or does this also include covered bonds acquired from other institutions (other banks - in addition to the already mentioned SPVs)? • Considering the scope of the template, the exposures to be reported refer to the loans collateralized by the immovable properties securing the bonds, and not the value of the bonds themselves, is that correct? • Should the total amount be reconciled with a specific cell in the FINREP reporting framework?   Thank you in advance for your kind clarification.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7600
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 12/01/2026

COREP CVA Risk reporting – exempted CCP-related transactions

In case of an institution that is also a clearing member to a QCCPs, for its CCP-related transactions that are exempted from CVA own funds requirements under CRR article 382(3), should these be reintegrated/reported in COREP template C25.01 row 0050?

  • 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_7597
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 12/11/2025

COREP Template 236. Specialised Lending Supervisory Slotting Method

How should institutions reflect, in COREP template C 08.01, credit risk mitigation (CRM) techniques applied to exposures subject to the slotting approach?

  • 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_7596
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

ASF factors for Additional Tier 1 items as wells as Tier 2 items and other capital instruments maturing between 6 month and 1 year

For the purpose of calculating the NSFR, which appropriate available stable funding factor shall institutions apply for Additional Tier 1 items as well as Tier 2 items and other capital instruments maturing between 6 month and 1 year?

  • 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 (repealed)
  • ID: 2021_6017
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 07/10/2025

Customers short sales internally matched with other clients’ long positions, as part of primary brokerage services

What is the expected treatment in the Liquidity Coverage Ratio of an internalized transaction, maturing within 30 calendar days, where the institution grants a margin loan to a client against a collateral that does not qualify as liquid assets and where this collateral is lent to another client to cover short sales?

  • 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: 2025_7595
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 10/11/2025