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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

Financial Conglomerates: Mismatch between ITS and DPM 3.5 – ID v22748_u - T1 L 06.00, column c0020.

We are seeking clarification about a possible mismatch between ITS and DPM 3.5 (ID v22748_u - T1 L 06.00, column c0020) as part of the compilation of the template FC.06 Template - “Risk Concentration - Exposure by counterparties" within the FiCod. supervisory reporting. The Commission Implementing Regulation (EU) 2022/2454 of 14 December 2022 states that, within the Template FC.06 - “Risk Concentration - Exposure by counterparties", the exposures must be reported for each individual legal entity belonging to the financial conglomerate, whereas the DPM 3.5 only permit reporting a unique value of the identification code of the external counterparty. This also determines the impossibility of representing separately the exposures held towards the same external counterparty but denominated in different currencies. We therefore ask what is the correct way to represent - inside the FC.06 Template- the cases in which multiple entities belonging to the conglomerate have exposures towards the same external counterparty and for the cases in which, for each external counterparty, there are exposures denominated in different currencies.

  • Legal act: Directive 2002/87/EC (FiCoD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2454 – ITS on the reporting of intra-group transactions and risk concentration for financial conglomerates
  • ID: 2025_7381
  • Topic: Financial conglomerates
  • Date of submission:

Recognition of non-transferable liquidity held by and arising in third country subsidiaries in the context of the calculation of the consolidated LCR

What is the (combined) treatment of liquid assets held by and liquidity inflows arising in third country subsidiaries being subject to transfer restrictions for the purpose of the calculation of the LCR at consolidated level?

  • 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_7375
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 27/03/2025

XBRL Modelisation of FICOD REPORTING L0600

It seems that the current modelisation L0600 only accepts as a dynamic dimension the column 0020 "identification code of the exernal counterparty" where the ITS states that :  -1) General ITS : "the aim is to list the significant exposure [...] by single counterparty outside the scope of the financial conglomerate. If more than one entity of the financial conglomerate is involved, for entity a separate line is necessary"  2) ITS L0600 - c0080 :  The name of the enity of the conglomate involved in the exposures. It concerns all entities and for each entity a separate entry has to be reported. If more than one entity of the conglomerate is invoved, for each entity a separate line is necessary.   So normally the report shoud have two key dynamisms a the row level : 0020 "identification code of the exernal counterparty" 0080 "Entity of the financial conglomerate' Can you confirm that with the current XBRL settings it's not possible to correctly submit the informations as expected by the ITS? Can you propose a workaround ?

  • Legal act: Directive 2002/87/EC (FiCoD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7370
  • Topic: Financial conglomerates
  • Date of submission:
  • Published as Rejected Q&A: 28/04/2025

Table F12.01 – Movements in allowance and provisions for credit losses

Considering the greyed out columns in row 350 and 550: How can the actual movement of impairment be reflected correctly?

  • 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_7365
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 25/03/2025

Prudential treatment of goodwill and other intangible assets arising from the acquisition of an asset manager by an insurance undertaking fully owned by a bank

For the purposes of a deduction under Articles 36(1)(b) and 37 of the CRR, should a bank, which owns 100% of an insurance undertaking which acquires a controlling shareholding in an asset manager, deduct goodwill and other intangible assets (Article 4(1)(113) and (115) of the CRR) generated by the acquisition carried out by its insurance undertaking subsidiary?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7349
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 27/03/2025

breakdown of total exposures by risk weights

How should exposures subject to a risk weight of 70% according to Art. 126 (2) CRR3 be reported in the ITS on supervisory reporting v4.0? Should these exposures be included in the row r0280 “other risk weights” of the template C 07.00?

  • 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_7348
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 21/03/2025

Presentation of fully matured loans and deposits in templates F05.01 and F08.01

Could you please clarify how fully matured loans and deposits should be presented in templates F05.01 and F08.01?

  • 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: 2025_7344
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/03/2025

Treatment of Net Interest Income Stress Outlier Test (NII SOT) in scenarios where breaches occur due to one-off effects (EBA/RTS/2022/10)

Could you please provide guidance on how banks should approach the reporting of such NII SOT breaches arising from such short-term, non-structural events and in addition how is it foreseen that the regulator should govern such cases? Specifically, are there any provisions or considerations that can be applied to account for these temporary effects without misrepresenting the bank's overall NII sensitivity? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 530/2014 - RTS on materiality of thresholds for internal approaches to specific risk in the trading book
  • ID: 2025_7343
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 03/03/2025

Counterparty classification

On FINREP reports, each counterparty is classified into a counterparty type, like Household or Government. Some government services are provided by volunteers, which raises the question how this should be classified, since the people are technically not employed by the government. Examples include volunteer police or volunteer firefighters and their unions, whose members provide and/or facilitate services specific to governments.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7342
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 11/04/2025

Template EU MR4 missing from Annex

The EBA Pillar 3 mapping tool mentions template EU MR4. I cannot find this in any of the annexes. Is this template relevant?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/11 - Guidelines on disclosure requirements under Part Eight of CRR
  • ID: 2025_7339
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 28/02/2025

Definition of ‘subordinated liabilities’ for FINREP reporting

What should be considered as ‘subordinated liabilities’’ for financial reporting purposes in FINREP template 8.2? Does definition of “subordinated liabilities” include also MREL instruments that do not qualify as Common Equity Tier 1, Additional Tier 1 or Tier 2 items meaning and have characteristics defined in the Article 72b(2) of CRR? 

  • 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_7337
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/03/2025

Scaling of gross JTD amounts of securitisation tranches with a maturity less than one year

Should the tranche maturity (MT) of less than one year of gross JTD amounts of securitisation tranches resulting from either formula in Art. 257(1) CRR be floored at one year as required by para. 2 of this Article, or can the MT be used without this floor of one year in order to enable scaling, with a floor of three months, as prescribed by Art. 325z(5) CRR in conjunction with Art. 325x(3) CRR? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7335
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 11/04/2025

Definition of Delta GIRR risk-free interest rate curves

Which risk-free interest rate curves per currency should be considered as different curves? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7334
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 11/04/2025

Sign convention on EVE, NII and MV levels in Template J_01.00 and J_02.00

If the value of EVE,  NII and MV level in columns c0030, c0100, c0130 of template J_02.00 result in a negative sign, is it correct to input a positive sign in template J_01.00 for the same items as requested by the validation rules?

  • 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_7333
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 21/02/2025

Exemption from approval for financial holding companies or mixed financial holding companies as per Directive 2013/36/EU (CRD) Article 21a (4) (d)

Should the criterion in Article 21a (4) (d) CRD (engagement in taking management, operational or financial decisions affecting the group or its subsidiaries) be considered to be met if the some persons are represented on the governing bodies of both the (mixed) financial holding company and an institution that is a subsidiary?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7330
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 03/03/2025

Reported amount in F09.02 col0010 if overcollateralization can occur

How should financial guarantees be reported in F09.02 if the value of the guarantee exceeds the loan exposure (possible overcollateralization)?Example:There is a credit risk mitigation group including 2 financial guarantees and 1 loan exposure as follows:Financial guarantee nr.1 - 15 000 EURFinancial guarantee nr.2 - 17 000 EURLoan exposure - 14 000 EURReported amount in F09.02 col0010 = ?

  • 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_7328
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 28/02/2025

Date of Disclosure

CRR Art. 433 states that the disclosure should happen the date of the publication of the financial statements. Due to the imlempentation of CRR III EBA granted an extention to submit Q1 regulatory reports to the 30.06. How should the disclosure be handled?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/11 - Guidelines on disclosure requirements under Part Eight of CRR
  • ID: 2025_7327
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 28/02/2025

Validation rules taxonomy V4.0 C08.01 v4770_m

The formula v4770_m specifies that for C08.01, the total sheet is the sum of all the IRB Foundation sheets, including the memorandum items.However, Final ITS instructions specify that memo subcategories must be reported separately as a subclass of exposure, not linked to the total IRB exposures classes. Also, in the C02.00, lines with reference to memorandum items are shaded and not included in the totalization.The control seems incoherent.Could you please therefore confirm that sheets with reference to memo items should be removed from the formula?

  • 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_7326
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 26/02/2025

Validation rules taxonomy V4.0 C08.01 v4769_m

The formula v4769_m specifies that for C08.01, the total sheet is the sum of all the IRB Advanced sheets, including the memorandum items.However, Final ITS instructions specify that memo subcategories must be reported separately as a subclass of exposure, not linked to the total IRB exposures classes. Also, in the C02.00, lines with reference to memorandum items are shaded and not included in the totalization.The control seems incoherent.Could you please therefore confirm that sheets  with reference to memo items should not be taken into account in the formula?

  • 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_7325
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 26/02/2025

Validation rules taxonomy V4.0 C09.02 v6052_m

According to the formulae v6052_m : {r0150} = {r0010} + {r0011} + {r0012} + {r0013} +{r0020} + {r0030} + {r0060} + {r0132} +{r0140} in c0010, c0030, c0040, c0050, c0055, c0060, c0070, c0105, c0110, c0120, c0125, c0130 in C09.02 “CR GB 2”.This control ensures that the sum of exposures declared in line 0150 "Total exposures" is equal to the sum of lines 0010 "Central governments or central banks", 0011 "Of which: Regional governments or local authorities", 0012 "Regional governments or local authorities", 0013 "Public sector entities", 0020 "Institutions", 0030 "Corporates", 0060 "Retail", 0132 "Collective investments undertakings (CIU)" and 00140 "Equity" in CR GB 2.However, the line 0011 is an "of which" of the line 0010 which is also in the formula, this means that it will be doubly taken into account in the totalization.Could you please therefore confirm that the line 0011 should be deleted from the formula?

  • 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_7324
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 26/02/2025