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List of Q&A's

Template 3: reporting of negative values when targets are surpassed

How to report negative values in column f 'Distance to IEA NZE2050 in %*' in cases where sector targets are surpassed?

  • 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_7254
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 10/04/2025

Requirement for approval for IRB-implementation of acquired portfolios

May the acquisition of a portfolio of exposures, within the range of application of the IRB-system of an institution, be subject to requirement of approval due to triggering of the quantitative impact rule in (EU) 529/2014 article 4?

  • 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: 2024_7253
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 01/05/2025

Meaning of ‘intragroup’ for the purpose of reporting in COREP template C 66.00 and C 68.00

What is the scope of ‘of which from intra-group entities’ for the purposes of classification of funding in COREP template C 68.00, row  190 (2.2.4) and in template C 66.00? 

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)
  • ID: 2024_7252
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 28/04/2025

IRRBB - Notional amount to be reported in column 0100

The notional amount to be reported in column 0100 represents the outstanding principal amount of the instruments (according to Implementing Regulation (EU) 2021/451, Article 20a and Annex XXIX specifying the reporting instructions); The notional repricing cash flows reported in columns 0700 to 0250 for fixed rate instruments include cash flows arising from both principal and interest (as defined in Article 1, point 1 of Delegated Regulation (EU) 2024/857).

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)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: 2024_7251
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 28/04/2025

v22331_s (IRRBB) - non-negative rule not applicable to some rows

Validation rule v22331_s ({J 03.00} >= 0) should not be applied on rows r0140, r0160, r0170, r0470, r0490, r0500 for column c030 (Level of EVE - Baseline scenario). Could you pls adjust the validation rule?

  • 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_7248
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 28/04/2025

Regulated financial service

In case of a “regulated financial service” provided by a financial entity authorized / licensed / registered as financial entity to deliver that service, shall it be considered an ICT service in the meaning of DORA?  

  • Legal act: Directive 2022/2556/EU (DORA Dir)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7246
  • Topic: Other DORA topics
  • Date of submission:
  • Published as Rejected Q&A: 18/02/2025

NACE sector K- 'Financial and insurance activities' in F 06.01

Can EBA confirm that Holding companies, as defined in ESA 2010, are out of scope of template F06.01? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7245
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 13/01/2025

Should repricing coupons be included in J06 sheets?

Should repricing coupons be included in J06 sheets in IRRBB reporting? EBA’s validation formula says that repricing coupons should not be included (validation rules v22320_m and v_22321_m). Otherwise the regulation (Final Draft RTS on Standardised Methodologies on IRRBB, Article 1, “’Notional repricing cash flow’ means: (c) Any interest payment on a part of the principal that has not yet been repaid or repriced) says that repricing coupons should be included. And if those repricing coupons are included (as the regulation says) it will cause validation rules v22320_m and v22321_m to be active because repricing notionals are always greater than the notional only.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7244
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 28/11/2024

v16332_s (IRRBB) - non-negative rule not applicable to some rows

Could you pls remove r0030 and r0150 from the scope of validation rule v16332_s?

  • 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_7243
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 28/04/2025

Application of recognised SyRB on a consolidated basis

May or shall a competent or a designated authority from a Member State, that recognises a systemic risk buffer rate set by another Member State in accordance with Article 133 of the CRD, require its domestically authorised institutions to apply that rate on a consolidated basis, covering all exposures targeted by the recognised systemic risk buffer held through subsidiaries, branches or through cross-border lending, in accordance with Article 134 of the CRD ? Does the legal framework permit or require that exposures of domestically authorised institutions held through subsidiaries located in the Member State that sets the buffer rate as well as in other Member States are also included in the scope of recognition? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7242
  • Topic: Other issues
  • Date of submission:
  • Published as final Q&A: 23/05/2025

FINREP Template F01.01

We would like to seek clarification regarding the classification of repurchase agreements (repos) in the context of the FINREP reporting framework.Specifically, we am inquiring whether repurchase agreements with a maturity of less than or equal to one day, where the counterparty is a credit institution, can be reported under row 0040 (Other demand deposits) in report F01.01.

  • 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: 2024_7241
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2025

FINREP Templates F25 and F13

It has come to our attention that Form F25.01.a contains data elements that overlap with Form F13.3.1. For instance, F25.01.a Row 0120 Column 0030 shares data with F13.3.1a Row 0020 Column 0010. From a business perspective, this inclusion appears incongruous, and we would appreciate an explanation of the rationale behind this decision. Could you please provide the logic and reasoning for including this shared data element between Form F25 and Form F13?

  • 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: 2024_7240
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 28/11/2024

Reporting Requirements on exposures subject to behavioural modelling

What is expected to be reported on the template J08.00b in terms of the perimeter of exposures included in the reporting of relevant parameters? Only those exposures actually subject to behavioural modelling by the institution (thus excluding exposures exposed to Prepayment, NMD behavioural modelling and Early Redemption Risks but non modelled by the institution) or all the exposures exposed to such risks, including those on which models are not 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 (repealed)
  • ID: 2024_7239
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 28/11/2024

Aggregated method for duration of derivatives

Could the EBA please clarify the expected method to aggregate and report the Duration value (column 0020) in template J 02.00 for derivatives?

  • 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: 2024_7238
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 28/11/2024

ESG P3 - Template 10 - Scope of disclosure and any relation to GAR related templates (Template 6, 7 and 8)

In Template 10, is the disclosure of the data identified at the counterparty / entity-level or data is identified at the exposure level? Can EBA help to also clarify when an exposure is reported in Template 10, would it be required for reporting in Template 6, 7 and 8 (only for the taxonomy aligned portion)?

  • 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_7237
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 20/03/2025

NACE 2025 reporting in ITS

The upcoming changes to the NACE (Nomenclature of Economic Activities) codes in 2025 are going to have certain implications for banks, particularly in relation to the ITS on supervisory reporting of institutions. For bank supervisory reports in 2025 in which data on NACE activity are requested, should the applicable NACE classification be based on the current NACE classification, or should the NACE activity codes be based on the NACE 2025 (which will be officially enacted on 1 January 2025)?

  • 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: 2024_7236
  • Topic: Supervisory reporting
  • Date of submission:
  • Published as Rejected Q&A: 23/05/2025

Classification as a “specialised debt restructurer” pursuant to Article 36 (5) of Regulation No 575/2013

To be classified as "specialised debt restructurer" (SDR), the institution’s sight deposits must not exceed 5% of the institution’s total liabilities. Within the context of the regulation, what is the appropriate interpretation of sight deposits when assessing if they meet the conditions from Article 36 (5) (f) of the Regulation (EU) No 575/2013? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7235
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 13/02/2025

Classification as a “specialised debt restructurer” pursuant to article 36 (5) of Regulation No 575/2013

For how long prior to an institution’s classification as a specialised debt restructurer must all the criteria specified in article 36 (5) of Regulation No 575/2013 be met by the institution?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7234
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 13/02/2025

Seniority categories to use when offsetting the gross JTD amounts of short exposures and long exposures within the DRC calculations for non-securitisations 

Which set of seniority categories shall be utilised and how should they be ranked as the basis for offsetting the gross JTD amounts of short exposures and long exposures within the DRC calculations for non-securitisations? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7233
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 17/01/2025

Vega general interest rate risk and credit spread risk factors

For credit instruments that include issuer-specific optionality, do both general interest rate vega and credit spread vega risk factors need to be considered as part of the SBM? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7232
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 17/01/2025