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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.

List of Q&A's

C.08.01 & C.08.02 - EBA VRs v09752_m & v09751_m

The EBA Validation Rules v09751_m and v09752_m applicable to the C.08.02 and C.08.01, respectively, state that  the column 170 (Own estimates of LGD's are used: other funded credit protection) must be equal to the sum of the  columns 171 (Cash on deposit), 172 (Life insurance policies) and 173 (Instruments held by a third party) for the following exposure classes: -  [eba_qAE:qx2022] - Total without own estimates of LGD or conversion factors- [eba_qAE:qx2020] - Central governments and central banks without own estimates of LGD or conversion factors-  [eba_qAE:qx2018] - Institutions without own estimates of LGD or conversion factors- [eba_qAE:qx2014] - Corporates - Specialised Lending without own estimates of LGD or conversion factors Should these controls be applicable?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Incorrect Quality Control check EGDQ_0764 for Annex I, INSTRUCTIONS FOR REPORTING ON SPECIFIC REQUIREMENTS FOR MARKET RISK, Template ({C90.00,r0010,c0080})

Data Quality ID EGDQ_0764 should be disabled as Total Assets reported in FRTB ({C90.00,r0010,c0080}) does not correspond to the amount reported in FINREP ({F01.01,r0380,c0010})

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/453 - ITS with regard to the specific reporting requirements for market risk

Template F 13.2.1.c VariableID 433471 and 433464

Following the most recent update to the FINREP validation framework under Reporting Framework 4.2., a new data point categorization has been introduced affecting template F 13.2.1.c, specifically Variable IDs 433471 and 433464. We would appreciate confirmation as to whether this data point categorization has been correctly defined and, if so, clarification on the prudential reporting rationale underlying it. Our concern is that the validation may not be conceptually appropriate in all cases, as not all additions of foreclosed assets necessarily qualify as non-current assets held for sale.

  • 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)

Exemption from deduction of Equity Holdings in an insurance company from CET1

Institution “A” currently applies the exemption provided under Article 471 CRR, whereby it does not deduct from its own funds a qualifying shareholding held in Insurance Undertaking “C” for an amount not exceeding the amount held in CET1 instruments issued by that Insurance Undertaking as of December 31, 2012 . Following the completion of a merger by absorption between Institution “A” and Institution “B” – as a result of which Institution “B”, as surviving entity, becomes the direct holder of the shareholding in Insurance Undertaking “C” by virtue of universal succession – is Institution “B” entitled to continue to apply the exemption under Article 471 CRR, as previously applied by Institution “A” in respect of such shareholding? Upon completion of the merger mentioned in question 1 above, would Institution “B” be entitled to apply the exemption under Article 471 CRR on a consolidated basis in case its direct shareholding in Insurance Undertaking “C” is transferred (as a result of a partial de-merger) to its wholly owned subsidiary Institution “D”, given that the shareholding in Insurance Undertaking “C” would in any event be held within the consolidation perimeter of Institution “B”? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

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

Classification of of CRR PSE under Finrep where local regulators identify them as a "non-CRR Bank"

Can a CRR PSE entity that qualifies as a Credit Institution under Article 4 of the CRR, be classified as a Credit Institution under FINREP, even if the local regulator classifies them as a "non-CRR Bank"?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

RESOL1 - how balance of cash collateral received as variation margin for intra group Repurchase Agreements should be reported in Z11.00 and Z02.00

How cash collateral received as variation margin for intragroup Repo trades be reported in Z11.00 and Z02.00 when the underlying Repo has already matured? What should be the insolvency ranking (c0030) of this balance intragroup variation margin in Z11.00?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Requirement for a consolidated ICARA process under Directive (EU) 2019/2034

Does Directive (EU) 2019/2034 require investment firms that are subject to prudential consolidation under Article 7 IFR to prepare, maintain and document an ICARA process on a consolidated basis? In particular, does Article 25(4) IFD impose an obligation to perform the ICARA at consolidated level, or does it merely extend the application of Part Three without creating a standalone consolidated‑ICARA requirement?

  • Legal act: Directive (EU) 2019/2034 (IFD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

v903250 incorrectly applied on exposure weighted averages

v903250_h is applied on (amongst others) column c0250 of C08.01, which relates to 'exposure-weighted average maturity value (days)'. The validation prescribes that r0010 should be larger or equal to rows 0015 and 0016. As in column c0250 a value-weighted average maturity is presented, it is not necessarily the case that r0010 exceeds r0015 and r0016. Therefore we feel this validation is incorrectly applied on c0250. with{tC_08.01.a, (c0020, c0030, c0040, c0050, c0060, c0070, c0080, c0090, c0101, c0102, c0103, c0104, c0105, c0106, c0107, c0110, c0140, c0150, c0160, c0170, c0171, c0172, c0173, c0180, c0190, c0200, c0210, c0250, c0255, c0256, c0257, c0260, c0270, c0280, c0290, c0300), default: 0, interval: true}: abs({r0010}) >= abs({r0015}) + abs({r0016})      

  • 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

Application and interpretation of the 50% / 80% weighting of positive changes under IRRBB SOT

How should Article 4(l) of the RTS on Supervisory Outlier Tests be interpreted in relation to the weighting of positive changes, in particular regarding: Whether the 80% weighting factor and associated cap should apply to EUR, given that EUR is not an ERM II currency. Whether the reference to “absolute value of negative changes in EUR or ERM II currencies” when calculating the cap should be interpreted as a sum of negative changes across all currencies or as a minimum reference between EUR and ERM II currency buckets. Whether the weighting of positive changes should be applied at the individual risk level or at an aggregated level?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Validation Rules in Reporting Framework 4.2

The question concerns the EBA Reporting Framework 4.2, Validation Rules (March 17, 2026), rule v23166, v23167 and v903615.v23166 concerns signs: with {tJ_02.00, c0020, default: null, interval: false}: {(r0010, r0030, r0040, r0050, r0060, r0070, r0080, r0090, r0100, r0110, r0120, r0130, r0140, r0150, r0160, r0170, r0180, r0190, r0200, r0220, r0230, r0240, r0250, r0260, r0270, r0280, r0290, r0300, r0310, r0320, r0330, r0340, r0350, r0360, r0370, r0380, r0390, r0400, r0410, r0420, r0430, r0440, r0450, r0460, r0470, r0480, r0490, r0500, r0510, r0520, r0530)} >= 0 Duration is the sensitivity of the economic value of a position towards interest rates. In case of derivatives the economic value can be positive or negative. Therefore, duration can also be positive or negative. Therefore, in some cases we can not comply with the current validation rulev23167 concerns signs:with {tJ_02.00, c0030, default: null, interval: false}: {r0010-0560} >= 0Under ‘Off-balance sheet assets: contingent assets’ we report the mortgage pipeline. These are forward starting loans; the notional still has to be paid out. Therefore, it is possible that the economic value of all future cashflows is negative. Per Q1 2026 this is the case (due to rising interest rate the past months).   Therefore, we cannot compy with this validation rules. v903615 concerns signs: with {tJ_02.00, c0130, default: null, interval: false}: {(r0530, r0570, r0580, r0600, r0610, r0620, r0640)} >= 0For derivatives it is possible that there is a negative economic value. For Q1 reporting this is not the case. But for future reference, this could be possibility and it may be possible that we can therefore not comply with this validation rule.  

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Validation of absolute totals in Template J.02 in ITS on IRRBB report

Should validation rule v903576_m_3 in template J.02 in ITS on IRRBB report be interpreted as requiring strict equality between: the absolute value of total risk (row 0200), and the sum of absolute values of the underlying components, even in cases where risk measures include both positive and negative values across balance sheet items?

  • 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

C08.01 - EBA VR v4757_m

The EBA Validation Rule v4757_m applicable to the C08.01 template states that the column c0280 (Expected loss) shall be lower or equal to the column 0020 (Gross exposure).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

C08.01 - EBA VR v10667_m

The EBA Validation Rule v10667_m applicable to the templates C.08.01 and C.08.02 COREP templates states that the Exposure-weighted average maturity value (days) of C.08.01 (column 250) of the row 70 (Exposures assigned to obligor grades or pools) multiplied by the total of the column 110 of C.08.02 (Exposure value) must be equal to the sum of the Exposure-weighted average maturity value (days) of C.08.02 (column 250) multiplied by the sum of the Exposure value of C.08.02 (column 110).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

C08.01 - EBA VR v903250_h

The EBA Validation Rule v903250_h applicable to the C.08.01 COREP template states that for the column 250 ('Exposure-weighted average maturity value (days)'), the absolute value of the row 10 (Total exposures) must be greater than the sum of the absolute values of the rows 15 (Of which: exposures subject to SME-supporting factor) and 16 (Of which: exposures subject to infrastructure projects supporting factor).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

C08.01 - EBA VR v4769_m

The EBA Validation Rule v4769_m applicable to the C08.01 COREP template states that for the columns 20 to 290 the total exposures (row 10) of the exposure class 'Total with own estimates of LGD and/or conversion factors' must be equal to the sum of the same cell for the exposure classes that have own estimates of LGD and/or conversion factors.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

C08.01 - EBA VR v09774_m

The EBA Validation Rule v09774_m applicable to the C08.01 and C.08.03 COREP templates states that the total of the Exposure value concerning credit risk in C.08.01 (column 110: row 10 - row 40 - row 50 - row 60 - row 80) must be equal to the total of the Exposure value post conversion factors and post CRM in C.08.03 (sum of all rows of the column 40).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

C09.02 - EBA VR v4786_m

The EBA Validation Rule v4786_m  states that EAD (c0105) should systematically be greater or equal to the RWA pre supporting factor (c0110) concerning the C09.02 template.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

C09.02 - EBA VR v903627_h

The EBA Validation Rule v903627_h applicable to the C09.02 template states that the row 0030 (Corporates) shall be equal to row 0050 (Of which: SME) plus the row 0051 (Of which: Large Corporates) for almost all the columns of the template.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

C10.00 - EBA VR v23089_m

The EBA Validation Rule v23089_m applicable to the C10.00 template states that the column 120 (IRB EXPOSURES SUBJECT TO COUNTERPARTY CREDIT RISK UNDER THE IMM) must be empty for all the rows except the rows 30 (SA exposure classes excluding securitisation positions) and 270 (SA exposures subject to counterparty credit risk under the IMM).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable