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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

Template F 16.08 validation rule eba_v8193_s

Is it possible to report negative amounts in r 0040 c 0010 (taxes and duties) due to VAT tax refunds from the previous 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)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: 2024_7176
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 31/10/2024

COREP C32_01 Fair Value changes of hedged items can be negative

Guidance for Row 120  of template C32.01 of EBA Framework Annex II Reporting on own funds and own fund requirements states that for Fair value changes of the hedged items in portfolio hedge of interest rate risk the amount of row 250 of template F01.01 should be inserted. However this row can contain a negative value and can be related to positions not in the trading book. In this case, when we comply with the instructions, submitting C32.01 is not possible since we get an error message that for row 0120 column 0090 is not smaller than row 0080. This is due to the fact that row 0120, col 0080 is a negative amount which corresponds as instructed with FINREP F01.01 row 250. Since it does not relate to positions in the trading book, row 0120, col 0090 is 0 and hence contains a bigger value.    

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)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_7171
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 25/03/2025

Signage of Model Risk Fair Value Adjustments reported in C32.02 (v6575_s)

Model Risk FVAs taken due to market or product factors not captured by a valuation model can be either positive (resulting in a P&L loss) or negative (resulting in a P&L gain).  Where the adjustment would result in a P&L gain, it should logically be populated with a negative value. However, validation rule v6575_s states that FVAs reported must be greater than or equal to zero. Please confirm if Model Risk FVAs resulting in a P&L gain should be reported with negative signage in column 0190 of the COREP C32.02 template.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/101 - RTS for prudent valuation under Article 105(14) CRR
  • ID: 2024_7170
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 25/03/2025

Reporting signage of Concentrated Position Size and Market Value in C32.04 (v7301_s)

Concentrate Position Size and Market Value can be negative depending on factors including direction of underlying positions (long or short).  Please confirm reporting signage for Concentrated Position Size (col 0040) and Market Value (col 0060) in COREP template C32.04.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/101 - RTS for prudent valuation under Article 105(14) CRR
  • ID: 2024_7169
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 25/03/2025

Passporting procedure for CIs and EMIs issuing tokens under MICAR

Are articles 146 (for credit institutions) and 48(3) (for e-money institutions) to be interpreted as submitting credit institutions and e-money institutions issuing ART/EMT on a crossborder basis to comply with the existing passporting framework set for these categories of establishments respectively by directives 2013/36/EU and 2009/110/EC? 

  • Legal act: Regulation (EU) No 2023/1114 (MiCAR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7168
  • Topic: Other MiCAR topics
  • Date of submission:

Passporting procedure for non-CI ART issuers

Shall NCAs consider that articles 18, 21, 25 and 109 of MICA regulation set a specific passporting framework for “pure” ART issuers where: ART issuers are authorized to market tokens in Member States they declared during the authorization process as soon as they are authorized by home NCAs; within two working days of granting authorization, home NCAs only have to inform host national competent authorities, ESMA, EBA, ECB and competent national central bank of the Member States of the member states where ART issuers intend to market their token ; this information regarding passporting of ART issuers is publicly available on ESMA register? 

  • Legal act: Regulation (EU) No 2023/1114 (MiCAR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7167
  • Topic: Other MiCAR topics
  • Date of submission:

Publication of white papers

Regarding entities exempted from authorisation pursuant to Article 16(2) of MiCAR, they shall notify the white paper to the competent authority of the home Member State, and the NCA is responsible for forwarding on the white paper of these entities to ESMA. However, it is unclear how the white paper is made available to the intended audiences of customers, and other relevant stakeholders and investors. Article 28 on publication of crypto-asset white papers only refers to ‘approved’ white papers (in accordance with Article 17(1) or Article 21(1) of MiCAR), without referring to notified white papers of exempted entities under Article 16(2) of MiCAR. Therefore, does Article 28 on publication of white paper of ART issuers also applies to issuers exempted under Article 16(2) of MiCAR?"

  • Legal act: Regulation (EU) No 2023/1114 (MiCAR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7166
  • Topic: Authorisation of issuers of ARTs and EMTs (MiCAR)
  • Date of submission:

Compliance of non-bank PSPs with the safeguarding requirements in PSD2

Where PIs and EMIs (referred to as non-bank PSPs) have direct access to central bank operated payment systems for settling payment transactions, would keeping a balance on a settlement account with the central bank/payment system, without the central bank maintaining a safeguarding account for the non-bank PSP, be compliant with the safeguarding requirements under Article 10 of PSD2?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7165
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 08/05/2025

Definition of ‘project finance loans’ for FINREP reporting

What should be considered as ‘project finance loans’ for financial reporting purposes (FINREP)? Is deviation from definition of project finance referred to in Article 147(8) CRR (with regard to conditions a and b) justified?

  • 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_7164
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 20/12/2024

ALMM C66 taxonomy control – negative cells

Can you please review the severity of some taxonomy controls to be consistent with economic flows and the Joint Liquidity Template of the ECB?

  • 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: 2024_7163
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 31/03/2025

Calculation of the net open position for capital requirements for structural FX risk

In the context of article 352.2, in relation with the consolidated capital calculation for FX risk,  the historical cost at solo basis must be taking into account or not?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2020/09 - Guidelines on the treatment of structural FX under Article 352(2) of CRR
  • ID: 2024_7162
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 15/11/2024

Calculation of the capital requirements for structural FX risk

In the context of article 352.2, when there is an investment in a subsidiary denominated in foreign currency and this subsidiary has invested in other subsidiary denominated in the same foreign currency must this exposure be always exempted from capital requirements calculation? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2020/09 - Guidelines on the treatment of structural FX under Article 352(2) of CRR
  • ID: 2024_7161
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 29/08/2024

Offsetting position among all group entities without the permission of 325b

In the context of article 352, when an institution is following a strategy of hedging the consolidated CET1 ratio (as opposed to hedge at solo level) and has been granted the waiver in art 352.2 at a consolidated level but when the permission in article 325b is not granted: Is it necessary to have the netting permission of Article 325b granted to take into account shorts open position in a subsidiary to calculate the structural FX position at consolidated level, for the waiver application purposes? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2020/09 - Guidelines on the treatment of structural FX under Article 352(2) of CRR
  • ID: 2024_7160
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 15/11/2024

Consideration of additional items in the calculation of the net open position or maximum net open position

In the context of art 352 (2) the calculation of the net open position  or maximum net open position in the context of Structural FX framework should take into consideration items affecting the capital ratio but not directly related to assets, liabilities or off-balance items such Additional Value adjustment or minority interests denominated in FX currency? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2020/09 - Guidelines on the treatment of structural FX under Article 352(2) of CRR
  • ID: 2024_7159
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 15/11/2024

NACE CODES

Can we expect changes in the reporting templates for new updated NACE (NACE REV. 2.1)?

  • 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_7158
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 20/12/2024

Retail deposit - an established relationship criteria

For the purpose of article 24 paragraph 1(a) a retail deposit shall be considered to be part of an established relationship where the depositor meets at least one of the following criteria:  (a) has an active contractual relationship with the credit institution of at least 12 months duration;(b) has a borrowing relationship with the credit institution for residential loans or other long term loans;(c) has at least one other active product, other than a loan, with the credit institution.   Could you give an example what is considered to be 'one other active product, other than loan'?  Would it be correct to consider these products as 'one other active product, other than loan' to fulfill the crieteria c): credit card debt; hire purchase; financial lease ?

  • 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: 2024_7157
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 29/08/2024

Failed rule EGDQ_0875 – proposed check on 12/2023 FP

How to cope with the issue described below for the future EBA Funding Plan deliveries avoiding any “failed” rule?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
  • ID: 2024_7156
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as Rejected Q&A: 31/01/2025

Simultaniously use of the SME and infrastructure factor

Please see the existing question, which was not answered yet: 2020_5551

  • 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: 2024_7155
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 29/08/2024

The OFR calculation are performed in local currency (reporting currency in the jurisdiction for the subsidiary) and then converted to EUR (group reporting currency) for consolidation

Under current (No FRTB) Own Funds Requirements (OFR) framework for Market Risk. A bank composed by a parent entity in Europe and a subsidiary in a third country.  With approved use of Internal Model Approach for all risk factors where no offsetting of positions is allowed between both entities (parent and subsidiary) and not permission described in article 325 of CRR granted. Some residual risks calculated under Standardized Approach. So, according with the IMA permission and TRIM guides, the OFR calculation for market risk at consolidated level is the addition of 4 elements: OFR under IMA for parent + OFR under IMA for subsidiary + OFR under SA for parent + OFR under SA for subsidiary. For the subsidiary, the OFR calculation are performed in local currency (reporting currency in that jurisdiction) and then converted to EUR (group reporting currency) for consolidation. The required Banking Book positions (i.e. FX and commodities) are capitalized for market risk under this schema. Is this calculation compliant with CRR (current version of OFR, not FRTB reporting and future OFR)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7154
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 24/09/2024

MREL-REPORTING OF THE IMPACT OF GENERAL PRIOR PERMISSION

With reference to the Q&A 6852, we kindly request clarification on the appropriate logic to utilize when adding the amounts of the unused portion of the GPP for the rows in Template M 01.00, specifically rows 0250 to 0290. We would greatly appreciate if you could provide guidance on the correct allocation of the unused amount for rows 0260, 0270, 0280, 0285, and 0290. Given that the GPP has a duration of one year, it is our understanding that the unused amount should be accounted for solely in rows 0250 and 0285, as per convention.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/763 – ITS with regard to the supervisory reporting and public disclosure of MREL
  • ID: 2024_7153
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 14/03/2025