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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

Exposures to institutions waived from individual capital requirements according to article 7 CRR, under Credi Risk Standarised Approach

How should exposures to institutions be treated under Credi Risk Standarised Approach, if such institutions have been waived of individual capital requirements? Shall these exposures be assigned to grade C, or can the level of compliance with capital requirements be assessed by taking consolidated requirements as reference?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7363
  • Topic: Credit risk
  • Date of submission:

Calculation of risk-weighted exposure amounts for off-balance exposure in case of Unfunded Credit Protection (UFCP)

What is the correct treatment in cases where the consideration of CRM according to articles 235, 235a or 236 leads to higher calculated risk-weighted exposure amounts than those calculated without considering CRM, even when the risk weight of the protection provider is lower? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7357
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

Calculation of risk weights

How should institutions calculate a risk weight amended for credit protection in accordance with Chapter 4?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7356
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

Calculation of the SME supporting factor for off-balance-sheet exposures

Is the SME supporting factor applicable, and if so, how shall it be computed, in case there is no on-balance-sheet exposure to be included in E*, as defined in Article 501(1) of CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7350
  • Topic: Credit risk
  • Date of submission:

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

Validation rules taxonomy V4.0 C09.02 v23650_h

According to the formulae v23650_h : {r0030} = {r0050} + {r0051} in c0010, c0030, c0040, c0050, c0055, c0060, c0070, c0105, c0110, c0120, c0121, c0122, c0125, c0130 in C09.02 “CR GB 2”.This control makes the comparative between r0030 “Corporates” and the sum of lines r0050 “Of Which: SME” and r0051 “Of Which: Large Corporates" in CR GB 2.However, in Annex 2, the instructions for line 0030 refer to Article 147(2), point (c), of Regulation (EU) No 575/2013 which classifies Corporates as the following : i)General Corporate, ii) Specialized financing exposures and iii)Purchased receivables. The control seems incoherent since lines r0050 and r0051 expect "of which" items.To be compliant with the corporate categories defined in Article 147, line 0030 should be compared with the totalization of lines 0052 "Specialized lending", 0057 "Purchased receivables" and 0058 "Others".Could you please therefore confirm that the control needs to be modified?

  • 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_7323
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 26/02/2025

CCF of items (b) and (c) of bucket 5 from 2025 to 2032

Which credit conversion factor shall be applied to the undrawn amount of retail credit lines for which the terms permit the institution to cancel them to the full extent allowable under consumer protection and related legal acts (item listed in point (b) of bucket 5), and to undrawn credit facilities for tender and performance guarantees which may be cancelled unconditionally at any time without prior notice, or that do effectively provide for automatic cancellation due to deterioration in a borrower’s creditworthiness (item listed in point (c) of bucket 5) in the years 2025 to 2032?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7318
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 23/04/2025

Internal Model Method

What is the prudential treatment of cash flow spikes in the calculation of own funds requirements for counterparty credit risk under the Internal Model Method?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7303
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 21/05/2025

Requirements for the purpose of treating exposures secured by mortgages on immovable property as duly secured from an RWA computation perspective under CRR Article 124(2) of the CRR.

Can a global insurance against damages on a portfolio of exposures secured by immovable properties subscribed directly by the lending institution be considered as compliant with the requirement of Article 208(5) of the CRR - that is to say considered, under the standardized approach, as meeting the operational requirements for the purpose of treating exposures secured by mortgages on immovable property (or in case an institution has opted for the application of article 108(5)(a) allowing to consider a guaranteed exposure as an exposure secured by a mortgage on immovable property) as duly secured from an RWA computation perspective under Article 124(2) of the CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7293
  • Topic: Credit risk
  • Date of submission:

application of condition specified in Article 501a. (1) o) after January 1, 2025

Are we correct that after January 1, 2025, during the examination of compliance with the ISF factor, it is necessary to examine point o) only in the case of exposures originated after January 1, 2025, and in the case of previous exposures originated before 1 January 2025 the debtor is not obligated to carry out any assessment?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7259
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

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

Risk weighting attributed to gold in the form of a commodity

Is the definition of “gold bullion”, as amended by Regulation (EU) 2024/1623, more restrictive than the definition previously set forth in the Regulation (EU) No 575/2013 (CRR), or this new definition shall be interpreted applying the clarification provided by the EBA in the Q&A 2016_3011?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7228
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 03/06/2025

Use of credit assessments by ECAIs not in scope of Regulation (EC) No 1060/2009.

Can external credit assessments that have been issued by an ECAI, but were not publicly disclosed, be used to determine the risk weight of an exposure under the Standardised Approach?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7220
  • Topic: Credit risk
  • Date of submission:

Supervisory Factor for Credit Derivatives with underlying securitization for SA-CCR

The supervisory factor for the credit risk category add-on is to be assigned based on the rating assigned to the issuer of the underlying credit derivative.For securitisations, should the rating of the SPV issuing the various tranches be used or can the rating of the tranche be used? If the SPV is not rated but the tranches are, should the exposure be considered unrated?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7216
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2025

Volatility Haircuts for Eligible Securitisation Collateral

Does the FCCM approach apply to unrated senior securitisation tranches that qualify as eligible collateral (i.e, as per article 197(1)h, "securitisation positions that are not resecuritisation positions and which are subject to a 100 % risk weight or lower in accordance with Article 261 to Article 264")?  If so, which supervisory volatility haircuts apply since there is no CQS associated with these under Sec- SA?  In addition, the new securtisation mappings of ECAI Ratings CQS 1-18 under Sec-ERBA have not been translated into Table 1 of Article 224, which continues to refer to CQS 1-4 seemingly under the old securitisation rules.  Which supervisory volatility haircuts apply under the new CQS mapping for rated securitisation tranches (as described in Commission Implementing Regulation (EU) 2016/1801 of 11 October 2016, as Amended by Commission Implementing Regulation (EU) 2022/2365 of 2 December 2022)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7214
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 03/06/2025

Applying risk weight in accordance with Article 235(3) of CRR3

In case of exposure and guarantee denominated in different currencies, which currency shall be taken into account in the process of application of risk weight for guaranteed part of exposure in accordance with Article 235(3) of CRR3?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7213
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 04/07/2025

Remaining maturity of the transactions for collateralised transactions

As per CRR Article 162(2)(c)& (d)- This states (as per below). Can the term "remaining maturity" in the below paragraphs be defined as Margin Period of Risk for collateralised transactions and Contractual maturity for un-collateralised transactions? (c)  for exposures arising from fully or nearly-fully collateralised derivative instruments listed in Annex II and fully or nearly-fully collateralised margin lending transactions which are subject to a master netting agreement, M shall be the weighted average remaining maturity of the transactions where M shall be at least 10 days; (d)  for repurchase transactions or securities or commodities lending or borrowing transactions which are subject to a master netting agreement, M shall be the weighted average remaining maturity of the transactions where M shall be at least five days. The notional amount of each transaction shall be used for weighting the maturity;

  • 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: 2024_7204
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 07/03/2025

EBA publication on hard test results

Does EBA plan to publish information related to loss rates for immovable property markets in third countries? If yes, when is such a publication to be expected and which third countries will be covered?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7197
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 27/03/2025