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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

Permission to reduce own funds or eligible liabilities and deduction rules in the context of a liability management exercise (exchange offer, tender offer or issuance of a replacement instrument concurrent with a tender offer on the existing instrument)

Should deductions from own funds and eligible liabilities with regards to a permission to reduce own funds or eligible liabilities in accordance with Article 77 of Regulation (EU) No 575/2013 (CRR) in the context of a liability management exercise (exchange offer, tender offer or issuance of a replacement instrument concurrent with a tender offer on the existing instrument), rather than upon the exercise of a call option,  be made right after the permission from the competent authority / resolution authority is granted or could it be later at the time of the institution’s public announcement of the liability management exercise in accordance with Article 28(2) of the RTS on Own Funds? In that context, how should the concept of ‘sufficient certainty’ of Article 28(2) RTS be applied?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions
  • ID: 2023_6791
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 15/09/2023

Multi-licensed entity capital requirement

Whether a payment institution that also has a crowdfunding license must meet the capital requirements of both authorizations in aggregate?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6790
  • Topic: Authorisation and registration
  • Date of submission:

Reporting of marginal deposit facility amounts (overnight deposits with the central bank) in templates C72 and C74.

It is not clear how the amounts in Central Banks regarding the marginal deposit facility should be treated in the calculation of the LCR and reported in C72 and C74.

  • 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: 2023_6789
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 15/02/2024

Fraud reporting

How we should treat the transactions that are initiated by PSP (for example refunds, chargebacks, etc.), but those transactions are related to cardholder's actions.

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2018/05 - Guidelines on fraud reporting under PSD2 (amended by EBA/GL/2020/01)
  • ID: 2023_6788
  • Topic: Fraud reporting
  • Date of submission:

Assessing the level of concentration, measures and indicators

What is EBA's opinion regarding the inclusion or not in the determination of the Herfindahl-Hirschman Index (used for determining additional capital in case of credit risk concentration) of the exposures for which the RWA is zero (zero capital allocation) ?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2022/03 - Guidelines on common procedures and methodologies for the supervisory review and evaluation process (SREP) and supervisory stress testing under Directive 2013/36/EU
  • ID: 2023_6787
  • Topic: Supervisory review and evaluation (SREP) and Pillar 2
  • Date of submission:
  • Published as Rejected Q&A: 30/05/2023

Explanation regarding the term "non-reducible"

Could you please explain what does mean the term "nonreducible" in the context of life insurance policy pledged to a lending institution?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6786
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 20/07/2023

Algorithm to calculate the TOP Institution (resp. Shadow Banking) te report in C27 of Large Exposure Report

How to calculate the TOP 10 Institutions (resp. Shadow Banking) for GCC? Should be have to consider the exposure at countrepart level or consolidated level?

  • 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
  • ID: 2023_6785
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 29/06/2023

Reporting of deposit facility (overnight deposits with the central bank) in template C_66.01

It is not clear in which row of template C_66.01 the overnight deposits in central banks such as the deposit facility shall be reported.

  • 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
  • ID: 2023_6784
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 15/05/2023

C_81.00 ASF from capital items and instruments - Tier 2

It is written in article 428i (CRR2) that 'the amount of available stable funding shall be calculated by multiplying  the accounting value of various categories or types of liabilities and own funds by the available stable funding factors'. Concrete example: please give us the answer If credit institution has on balance sheet under Liabilities: (residual maturity for part of debt securities is more than 1 year and less than 5 years (2 000 000 eur) and other part has residual maturity more than 5 years) 1. Debt securities issued - 10 200 00 eur           1.1 Debt certificates - 10 000 000 eur           1.2 Interests payables on debt certificates - 200 000 eur   What amounts should be reported on NSFR C81.00 on row 0050, column 0030 - should it be 10 200 000 euros? Or amount is without interest - 10 000 000 euros? Or should it be equal to C01.00 row 0771 (where amortization is used for those debt securities that have residual maturity less than 5 years)? Also checked th Question: 2021_6016 - it does not give the aswer about the interests payables - should they be included or not?  

  • 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
  • ID: 2023_6783
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 09/10/2023

Securities lent under sale accounting (C40 and C43 treatment)

As per Q&A 6093, clarification has been provided on the disclosure treatment of securities lent in a repurchase transaction that are derecognized due to sales accounting transactions under the applicable accounting framework. The Q&A appears to state that institutions shall reverse all sales-related accounting entries and these securities are to be treated as SFTs in both C40 (row 071) and C43 (row 040 or 060) disclosure. Under sale accounting treatment, the requirement is to reverse the sale treatment and therefore the securities will be reported in its original form, which is expected to be trading portfolio assets. Given this, is the correct treatment not for securities to be reported in C40 (row 090) and C43 (row 070) respectively?

  • 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
  • ID: 2023_6782
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as Rejected Q&A: 28/09/2023

ESG P3 - Template 7 Decision tree KPI GAR for Households

In which row/group of rows from template 7 should be disclosed Households not included in the of which populated on the template (loans collateralised by residential immovable property, building renovation loans, motor vehicle loans)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2023_6780
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 25/08/2023

Discrepancy between definition of ‘investment holding company’ and ‘consolidated situation.’

Could a financial institution the subsidiaries of which are mainly tied agents or ancillary services undertakings, but which also has at least one investment firm as subsidiary, be considered an  investment holding company as referred to in Article 4(1)(23) IFR?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6779
  • Topic: Prudential consolidation
  • Date of submission:
  • Published as final Q&A: 22/03/2024

Reporting of Template C_67.00 including Concentration of Funding by Counterparty.

Since there is no clear guidance on how the above item should be treated, we are requesting feedback on whether the EBA has taken stance on how deposits coming through Online Deposits Platforms should be classified in the Concentration of Funding by Counterparty, template C_67.00, and for liquidity purposes in general. In addition, we would be interested in understanding whether such treatment would differ for other purposes such as Financial Reporting – as an example, the bank in the above scenario indicated that these deposits are in fact covered by DGS, hence indicating that for this purpose the counterparty is the direct household.

  • 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: 2023_6778
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 09/10/2023

Exchange rate mark-ups part of 'all charges payable'/'currency conversion charges'

Is an exchange rate mark-up (the difference between the interbank rate and the exchange rate offered by the PSP to its PSUs) to be considered as part of ‘all charges payable’ as per PSD2 and the ‘currency conversion charges’ as per CBPR2 prior to the initiation of the payment? How should PSPs disclose this in the payment flow? Article 45 of the PSD2 sets out the information and conditions that payment service providers (PSPs) need to provide to the payment service users (PSUs). Notably, Article 45 (1)(c) and (d) states that ‘all charges payable by the payment service user to the payment service providers and, where applicable, a breakdown of those charges’ as well as ‘the actual or reference exchange rate to be applied to the payment transaction’ should be shown to the PSUs.  The CBPR2 builds upon the requirements set out by PSD2, adding an additional layer of disclosures for cross-border payments within the EU.  Concretely, Article 5(1) of the CBPR2 refers to the provisions within Article 45(1) of PSD2 -  "When a currency conversion service is offered by the payer’s payment service provider in relation to a credit transfer, as defined in point (24) of Article 4 of Directive (EU) 2015/2366, that is initiated online directly, using the website or the mobile banking application of the payment service provider, the payment service provider, with regard to Article 45(1) and Article 52, point (3), of that Directive, shall inform the payer prior to the initiation of the payment transaction, in a clear, neutral and comprehensible manner, of the estimated charges for currency conversion services applicable to the credit transfer. Furthermore, Article 5(2) of CBPR2 further explains the necessary charges that need to be shown to the payer -  “Prior to the initiation of a payment transaction, the PSP shall communicate to the payer, in a clear, neutral and comprehensible manner, the estimated total amount of the credit transfer in the currency of the payer’s account, including any transaction fee and any currency conversion charges. The payment service provider shall also communicate the estimated amount to be transferred to the payee in the currency used by the payee.”    

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6777
  • Topic: Other topics
  • Date of submission:

Clarification on treatment of repurchase agreements and reverse repurchase agreement, as well as securities lending/borrowing of the banking book and of the trading book under the counterparty credit risk and the treatment of these same transactions under standardised approach of credit risk.

A securities repurchase (repo) is an agreement whereby a transferor agrees to sell securities to a transferee at a specified price and repurchase the securities on a specified date and at a specified price. Since the transaction is regarded as a financing (liability item) of the transferor for accounting purposes, the securities remain on the balance sheet of the transferor. As for the transferee the transaction is treated as a collateralized loan (asset item) for accounting purposes. When referring to “repurchase agreements” in art. 271 CRR, does it applies both to transferor and transferee exposures (in a manner analogous to securities lending transactions on which specific mention to both parties of a transaction –lending and borrowing- is made)? In essence, counterparty credit risk is a bilateral risk, and as such it seems reasonable to capture the risk of both counterparties, even if a transferor and a securities lender will both have accounted the operation as a liability item. Shall the institutions include all repurchase agreements and securities lending/borrowing for counterparty credit risk capital requirements purposes regardless of whether they have been accounted for within the trading or the banking book? According to article 271 (2) an institution shall include the exposure value of repurchase transactions and securities lending/borrowing for counterparty credit risk capital requirements purposes, without making any distinction as to whether they belong to the banking or to the trading book. The exposure value shall be calculated either in accordance with Chapter 4 or Chapter 6 of Title II. However, article 92 (3) (f) states that only SFT transactions of the trading book exposures are subject to counterparty risk capital requirements. Although it could be also interpreted that SFT transactions and agreements of the banking book are also subject to counterparty risk capital requirements according to article 92 (3) (a) as it refers to the whole Title II (including Chapter 6 –counterparty credit risk-). To make things even more confusing, according to article 111 (2) and article 166 (7) the exposure value of any repurchase agreements and securities lending/borrowing shall be included for credit risk capital requirements purposes and it shall be calculated either in accordance with Chapter 4 or Chapter 6. Following the argumentation set out above, the credit risk related to the counterparty in repurchase agreements and securities lending/borrowing of the banking book might be captured twice, once under the standardised approach/IRB method scheme (Chapter 2 or 3) and again under the counterparty credit risk regime (Chapter 6). It does not seem to make sense to ask institutions for capital requirements twice for the same risk concept. Can you please confirm which is the correct treatment for the credit risk related to the counterparty of repurchase agreements and securities lending/borrowing of the banking book? Or do articles 111(2)/116(7) refer to a risk concept different that article 271(2)? Do both parties of a same transaction –transferor and transferee, lender and borrower- have to capture the credit risk related to the counterparty? The same argumentation applies to derivatives, long settlement transactions and marging lending transactions of the banking book.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6775
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 27/07/2023

Treatment of repurchase agreements and reverse repurchase agreement, as well as securities or commodities lending/borrowing of the banking book under standardised approach of credit risk.

Shall the transferor of an operation like the one described below include for credit risk capital requirements purposes both the exposure value of the securities sold (asset item) and the financing position (even if it is a liability item), or just the asset item of the securities sold?According to Article 111(2) CRR the exposure value of any repurchase transaction shall be included and be calculated either in accordance with Chapter 4 or Chapter 6 of Title II: does it also refers to the financing position of the transferor (even if it is a liability item)?What is the correct treatment for the financing position of the transferor? are securities also to be included as an exposure value in case the Financial Collateral Simple Method is used?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6774
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 12/01/2024

Calculation of the amount reported for guarantees received on report F09.02

Should the amount of financial guarantees reported in F 09.02 be calculated considering (other) collateral?

  • 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
  • ID: 2023_6773
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 30/06/2023

Collateral swaps where the borrowed and lent collaterals are in different currencies

For a collateral swap where borrowed and lent securities are subject to the separate reporting  as referred to in Article 415(2) of Regulation (EU) 575/2013, we wonder how the transaction must be reported in the c75 , or eventually in 2 different transactions in c73 and c74 but in this case we don't know in which cells and with which weight.  For example, for a settled collateral swap where level 2B USD – market value of 150m is lent and level 2A EUR – market value of 120m is borrowed.  The amounts are already converted into the reporting currency. And we raise the same question if the transaction is forward starting in the LCR window and maturing outside.  

  • 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: 2023_6772
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 04/05/2023