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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

Risk weighting attributed to gold in the form of a commodity such as jewellery items for pawn credit business

Pursuant to the new definition of gold bullion under Article 4(1)(60a) of CRR, can gold in the form of jewelry items taken as collateral in a pawn loan qualify as "gold" and thus be eligible for prudential treatment in accordance with Article 134 CRR for the value based on the gold content (purity × mass), with no allowance for artistic, numismatic, branding or other extrinsic attributes to such jewelry?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7491
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 01/09/2025

Determination of exposure value cap for netting sets subject to a margin agreement.

Article 274(3) states "The exposure value of a netting set that is subject to a contractual margin agreement shall be capped at the exposure value of the same netting set not subject to any form of margin agreement". This wording has slightly diverged from Basel CRE52.2 which stated "The EAD for a margined netting set is capped at the EAD of the same netting set calculated on an unmargined basis".  Basel focused on applying the unmargined methodology in the wording not that it should be treated as if there were no margin agreement. This nuance in wording is leading to a misinterpretation of the CRR which is exacerbated by EBA Q&A 2023_6962 which has allowed for firms to apply SA-CCR in a manner which significantly underestimates capital requirements vs economic exposure. In situations where firms are posting excess variation margin which has a real economic credit risk to the counterparty the wording of the CRR and the Q&A implies that this can be fully disregarded from the exposure calculation. This would therefore mean that firms are able to arbitrage the capital rules and avoid capital charges by lending money to counterparties by posting it as variation margin under a CSA and then disregarding that exposure by applying the "unmargined" cap. This needs to be resolved by a clarification to the EBA Q&A to the effect that any collateral posted/received under a variation margin CSA should still be included in the exposure calculation, albeit using the unmargined rather than margined formulation to achieve the effect that the cap is designed to do per Basel CRE52.2 FAQ1.  i.e. this could easily be interpreted that if you are not subject to a margin agreement then anything which was variation margin should now just be characterized as NICA as it still economically exists as collateral. This would satisfy both the purpose of the rule and avoid the risk of understatement of capital requirements.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7478
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

Validation rules taxonomy V4.0 C07.00

The EBA Validation rules taxonomy v23005_m seems not relevant

  • 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_7475
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 26/09/2025

Eligibility as collateral under article 207(2) of secured notes designed specifically to remove any material positive correlation between the value of the note and the credit quality of its issuer.

Entity A issues a secured note designed specifically to remove any material positive correlation between the value of the note and the credit quality of its issuer (entity A). The note is secured by assets uncorrelated to entity A. In legal structure I, entity A deposits the assets with a third-party custodian trust account, pledged to the note holders.  In a variant legal structure II, entity A sells the assets to a SPV, which has been setup by entity A for that sole purpose; the SPV then issues a guarantee to the noteholders, backed by the assets it holds. Bank B enters into a reverse repo with entity A, where it lends cash to entity A and receives the secured note as collateral. From bank B’s perspective, does such secured note qualify as eligible collateral under CRR article 207(2) when: the secured note is secured by the assets held in a third party custodian trust account, pledged to the noteholders (legal structure I)? the secured note is guaranteed by a SPV holding the assets (variant legal structure II)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7470
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 24/10/2025

Validation rules taxonomy V4.0 C_08.01.a

Does the validation rule v23372_m should be applied to column 0250?

  • 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_7452
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C_10.00

The formulae seems irrelevant

  • 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_7450
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C_10.00

The formulae of the control seems irrelevant

  • 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_7449
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C_10.00

The formulae of the control seems irrelevant

  • 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_7448
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C_10.00

The formuale of the control seems irrelevant

  • 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_7447
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C_10.00

The formulae of the control v23054_m seems irrelevant

  • 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_7446
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C_10.00

The formulae of the control v23053_m seems irrelevant

  • 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_7445
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C_10.00

The formulae of the control v23052_m seems incoherent

  • 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_7444
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C_08.01.a,C_08.02,C_09.02

The EBA Validation rules taxonomy v7551_m seems not relevant.

  • 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_7443
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C_08.01.a,C_08.02,C_09.02

The EBA Validation rules taxonomy v7549_m seems not relevant.

  • 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_7442
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C08.01/C08.02

The EBA Validation rules taxonomy v10667_m seems not relevant.

  • 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_7441
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C08.01/C08.02

The EBA Validation rules taxonomy v10666_m seems not relevant.

  • 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_7440
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C08.01/C08.02

The EBA Validation rules taxonomy v10664_h seems not relevant.

  • 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_7438
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Inconsistency in the formulation of conditions for Hard Tests

Can Art. 199 para. 3, para. 4 CRR be interpreted in line with amended Art. 125 para. 2 sub-para. 3 and para. 3 sub-para. 1 6, 126 para. 2 sub-para. 3 and para. 3 sub-para. 1, 199 para. 4a CRR; hence, is it sufficient that a member state’s competent authority publishes loss rates despite different wording in Art. 199 para. 3, 4 CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7437
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 26/01/2026

Can a receivable be identified as IPRE if a mortgage exists, but the securing property is not recognised as collateral?

Art. 124 para. 1 stipulates that banks receive a risk weight of 150% for IPRE receivables that do not fulfil all the conditions set out in para. 3. The question is what constellation of conditions must be met for this case to realistically materialise. An institution should normally be able to fulfil subsections a to d in para. 3. Paragraph 3 contains a reference to Article 208 and paragraph 1 of Article 229 in sub-item e. Article 229 paragraph 1 describes the property valuation and will not generally present institutions with insurmountable problems either. Article 208 begins with the statement that a property is only recognised as collateral if the following paragraphs 2 to 5 are fulfilled. One hurdle could possibly be the monitoring of the property value in accordance with paragraph 3. However, it is also conceivable that an institution will generally refrain from recognising real estate collateral due to an insignificant share in the portfolio. Can a receivable that is effectively secured by a mortgage be identified as an IRPE risk position without recognised real estate collateral, resulting in an RW of 150% under Art. 124 para. 1? Or does non-recognition also mean that the exposure is not to be regarded as collateralised (by a property) for the calculation of own funds and consequently receives the risk weight of an unsecured exposure?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7434
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 31/07/2025

Reporting of COREP_OF C10.00 template

Are credit institutions that apply the Standardized Approach (SA) for credit risk and the Internal Model Method (IMM) for counterparty credit risk, in order to calculate exposure amounts of SA exposures, required to report template C10.00 row 0270 (Memo item)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2025_7433
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 19/09/2025