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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.

Please note that the Q&As related to the supervisory benchmarking exercises have been moved to the dedicated handbook page. You can submit Q&As on this topic here.

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List of Q&A's

SME supporting factor application on PSE exposures secured by immovable properties

Does Article 501 CRR allow application of the SME supporting factor in case (1) solely because of that reassignment to Article 112, point (i), even though the same obligor’s unsecured exposure in case (2) is not eligible?

  • 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: 2026_8011
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026

RW applicable to defaulted IPRE exposures

Given that Article 127(2) states that the secured part of a defaulted exposure considers collateral and guarantees eligible for credit risk mitigation under Chapter 4, and that real estate collateral is not regarded as eligible mitigation under the Standardised Approach (SA), while Article 127(3) applies the 100% risk weight only to non-IPRE exposures, should the risk weight (RW) for all defaulted IPRE exposures be determined according to Article 127(1), i.e., based on the level of specific credit risk adjustments?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7997
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026

Application of the risk weight of 100% to defaulted non-IPRE exposures

For non-IPRE defaulted exposures, is the 100% risk weight (RW) applicable only up to 55% of the property market value (LTV), or up to the full amount of the lien or mortgage value (if lower than the mortgage value)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7996
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026

Risk weight (RW) applicable to defaulted ADC and IPRE-Other exposures

For defaulted ADC and IPRE-Other exposures, should the applicable risk weight (RW) remain 150%, consistent with the RW applied before they become defaulted, or should banks apply the risk weighting rules set out in Article 127(1) of the CRR3?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7995
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026

Spot instrument on unallocated Gold are subject to counterparty risk

Are spot instrument on unallocated Gold subject to counterparty risk?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7994
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 22/09/2026

Collateral haircuts for third-country equivalent PSE-RGLA’s

For the purposes of Article 197(2)(a) and (b) CRR, should the references to PSEs and RGLAs in Articles 115(2) and 116(4) CRR be interpreted as encompassing the third-country equivalent entities referred to in Articles 115(4) and 116(5) CRR, such that debt securities issued by those entities qualify for the treatment provided under Article 197(1)(b) CRR? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7989
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Use of the EBA’s aggregated loss data for “All national markets outside the Union” for the purposes of Articles 125 and 126 CRR.

Does the row “All national markets outside the Union” in the EBA publication Immovable-property loss data, Q4 2025 constitute a publication of loss-rate data that may be relied upon, in respect of immovable property situated in Switzerland, for the purposes of the loss-rate requirements referred to in Article 125(3), second subparagraph, and Article 126(3), second subparagraph, CRR? In particular, may an institution use the losses and exposure amounts reported in that aggregated row to assess whether the applicable loss-rate thresholds are met for exposures secured by residential or commercial immovable property situated in Switzerland, notwithstanding that Switzerland is not presented as a separate national immovable property market?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7980
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Treatment of the secured portion of defaulted IPRE exposures under the Standardised Approach

Under the Standardised Approach for credit risk, Article 127(3) CRR states that: "The exposure value remaining after specific credit risk adjustments of non-IPRE exposures secured by residential property or commercial immovable property in accordance with Articles 125 and 126, respectively, shall be assigned a risk weight of 100 % if a default has occurred in accordance with Article 178." Articles 125(2) and 126(2) establish dedicated treatments for income-producing real estate (IPRE) exposures through ETV-based risk-weight buckets. Following the CRR3 amendments, Article 127(3) explicitly refers only to non-IPRE exposures and does not specify the treatment of the secured portion of IPRE exposures after default.  Could the EBA clarify the prudential treatment of a defaulted IPRE exposure that satisfies all requirements of Article 124 and is secured by residential property or commercial immovable property? In particular: Should the secured portion of a defaulted IPRE exposure continue to be risk weighted according to the ETV buckets in Article 125(2) or Article 126(2), as applicable? Alternatively, should the secured portion of a defaulted IPRE exposure be reported in the exposure class "Exposures in default" and be assigned a risk weight of 100%, analogously to the treatment laid down in Article 127(3) for non-IPRE exposures, despite IPRE exposures not being explicitly referred to in that provision   If neither of the above approaches is correct, what is the appropriate risk-weight treatment and COREP reporting treatment for the secured portion of defaulted IPRE exposures under the Standardised Approach? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7979
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

Application of the SME supporting factor to exposures financing private purposes following CRR III

Following the amendments introduced by Regulation (EU) 2024/1623 (CRR III), Article 501(2)(b) CRR defines an SME by reference to Article 5, point (9), CRR rather than to Commission Recommendation 2003/361/EC. Where the obligor is a natural person who carries out an economic activity and meets the turnover criterion in Article 5, point (9), should SME status be determined once at obligor level — so that the adjustment under Article 501(1) applies to all non-defaulted exposures to that obligor meeting Article 501(2)(a) — or should it continue to be assessed exposure by exposure by reference to the purpose of the individual financing, as set out in EBA Q&A 2021_6301?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7971
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

The control formula v11889_m lacks sufficient evidential value.

Only the Total sheet  ([eba_qAE:qx2023]) must be empty for column 0070 (LGD).  Should control over another sheet (other than [eba_qAE:qx2023]) really exist ? Should it not be deleted ?

  • 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: 2026_7952
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

The control formula v11888_m lacks sufficient evidential value.

Only the Total sheet  ([eba_qAE:qx2023]) must be empty for column 0050 (PD).  Should control over another sheet (other than [eba_qAE:qx2023]) really exist ? Should it not be deleted ?

  • 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: 2026_7951
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

The control formula v10666_m lacks sufficient evidential value.

The control rule in place is incompatible with the EBA Filing Rules - section 2.18 on decimal precision requirements. Could these rules be amended?

  • 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: 2026_7950
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

The control formula v10664_m lacks sufficient evidential value.

The control rule in place is incompatible with the EBA Filing Rules - section 2.18 on decimal precision requirements. Could these rules be amended?

  • 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: 2026_7949
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026

Risk weights assignment to IPRE exposures secured by many properties

Articles 125 and 126 paragraph 2 Regulation (EU) No 575/2013 (CRR) specify the rules for risk weights assignment to IPRE exposures, respectively secured by residential and commercial properties. However, these regulations don’t clarify how risk weights should be assigned to IPRE exposure when it’s secured by both residential and commercial property – especially when one property is IPRE (income producing property) and the second one is non-IPRE (the residential property, let’s assume that this is the flat of a counterparty). 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7923
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 06/07/2026

Clarification of ETV calculation for mortgages securing more than one exposure

Article 124 paragraph 6 Regulation (EU) No 575/2013 (CRR) specifies the calculation of ETV for IPRE exposures. In order to calculate ETV, the gross value of an exposure should be divided by the value of property. Additionally, this article clarifies that: “For the purposes of the first subparagraph, point (a), where an institution has more than one exposure secured by the same immovable property and those exposures are secured by liens on that immovable property that are sequential in ranking order without any lien held by a third party ranking in-between, the exposures shall be treated as a single combined exposure and the gross exposure amounts for the individual exposures shall be summed up to calculate the gross exposure amount for the single combined exposure.” Our question refers to calculation ETV for joint mortgages – so the mortgage which secures more than one exposures and additionally these exposures may have other mortgages assigned. Based on the above, it’s clear that numerator should include the gross value of all exposures secured by this joint mortgage. Nevertheless, it’s unclear which value should be used in the denominator of ETV in the real life example described below.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7922
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 06/07/2026

Treatment of the Right Way Risk in Call Warrant

Is a call warrant issued by the counterparty  that is also the issuer of the underlying shares exempt from counterparty credit risk requirements?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7911
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2026

IPRE and Property Collateral for Credit Risk Mitigation

When assessing the eligibility of immovable property collateral for the purposes of credit risk mitigation (CRM), how should institutions interpret the interaction between the definition of income‑producing real estate (IPRE) exposures in Article 4(75b) CRR and the conditions set out in Article 199(2) CRR for recognising immovable property as eligible collateral under the IRB approach? In particular, can immovable property collateral be recognised for CRM purposes under Article 199(2) in situations where an exposure is classified as IPRE under Article 4(75b), where repayment of the exposure is supported by diversified rental income streams across multiple properties or tenants, such that the repayment of the facility does not materially depend on the performance or cash flows of any single underlying property?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7898
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 09/10/2026

Validation rules taxonomy V4.2 C09.02 v903627_h

In the latest set of EBA validations rules, VR v903627_h has been added effective 31/03/2026. This validation rule is identical to the earlier deactivated v23650_h. Via 2025_7323 it was earlier raised that v23650_h is not correct. Hence, we feel that the same applies to v903627_h. 

  • 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: 2026_7864
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

Incoherent formulae of the validation rule v22949_m

Is the formulae of the validation rule v22949_m coherent?

  • 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: 2026_7863
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/09/2026

Incoherent formulae of the validation rule v4786_m

Should the validation rule v4786_m be active?

  • 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: 2026_7857
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/10/2026