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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.

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List of Q&A's

Reporting of ESCROW accounts (or other captive accounts) in template F08.01

In which row shall be reported Escrow accounts (or other captive deposits) from non financial companies in template F 08.01 ‘Breakdown of financial liabilities by product and by counterparty sector’?  Either as being ‘Current accounts/overnights deposits’ row 0270 or as ‘Deposits redeemable at notice’ row 0290 or as ‘Deposits with agreed maturity’ row 0280?  

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)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_7262
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 09/01/2025

Obstacles Faced by PISPs in Accessing Payment Status Information Under PSD2

Are ASPSPs allowed to require PISPs to provide any additional identifier beyond what is specified in Article 35.4.b of the RTS in order to access information about the execution of a payment order?

  • 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_7261
  • Topic: Other topics
  • Date of submission:

Application of DORA Regulation to sub-threshold AIFMs which have chosen to opt-in to the application of the AIFMD (Art. 3(4)), if the thresholds regarding AuM referred to under Article 3(2) of AIFMD are not exceeded

Are sub-threshold alternative investment fund managers (AIFMs) as referred to in Article 3(2) of Directive 2011/61/EU (“AIFMD”), which have chosen to opt-in to the application of the AIFMD according to Article 3(4) of that Directive, captured within the scope of application of Regulation (EU) 2022/2554 (“DORA”) under Articles 2(1)(k) and 2(3)(a) of DORA, if the thresholds regarding assets under management (“AuM”) referred to under Article 3(2) of AIFMD are not exceeded by such AIFM?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7260
  • Topic: Other DORA topics
  • Date of submission:
  • Published as Rejected Q&A: 18/02/2025

Equity instrument subject to impairment in F20.04

The instructions for reporting the column "of which: financial assets subject to impairment [...]" regarding equity instruments (see F20.04 r0040 c0012) currently leave room for interpretation about the specific definition of "subject to impairment" to be applied. In particular, we would kindly ask the EBA to clarify whether a) the respective positions should be deactivated (i.e., greyed out) because of non-applicabilityb) there is a different expectation regarding equity instruments that has not been written in the Annex yet (in particular, equity instruments are subject to the IAS 36 impairment test).

  • 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_7258
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 09/01/2025

Correlation EBA_v7336

Please, review the EBA_v7336 correlation.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7257
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 13/02/2025

Direct contributions to reserves from shareholders

Which conditions should direct contributions to reserves from shareholders meet when assessing their conformity with the criteria contained in the last subparagraph of Article 26(1) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7256
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 07/02/2025

emission allowances

Sentence 2 of paragraph 3 of Annex II CRR refers to point (11) of Section C of Annex I MiFID, i.e. to emission allowances. Does that mean that spot market emission allowances are to be treated as derivative contracts listed in Annex II, even though they are not derivative in character?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7255
  • Topic: Other issues
  • Date of submission:

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

Calculation of the Exposure-to-Value

How should be calculated the Exposure-to-Value (ETV) where a loan is secured by a combination of several liens on multiple properties (both residential and commercial) ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7247
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 03/06/2025

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