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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

Is the definition of 'gold bullion', as recently amended by Regulation (EU) 2024/1623, consistent with the previous definition of 'gold' under Regulation (EU) No 575/2013 (CRR), as clarified by EBA Q&A 2016_3011, in the sense that it includes all forms of gold commodities (such as bars, ingots, jewels, manufactured products, and coins) whose value is determined exclusively by gold content—defined by purity and mass—regardless of their form, provided that no numismatic, artistic, branding, or other extrinsic value is attributed?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7423
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 01/05/2025

Calculation of the Exposure-to-Value (ETV) ratio and risk weighting when dealing with complex collateral structures

Under Articles 124, 125, and 126 of Regulation (EU) No. 575/2013 (CRR) as amended, how should institutions calculate the Exposure-to-Value (ETV) ratio and apply risk weighting when dealing with complex collateral structures involving multiple liens, syndicated financing, and mixed property types? Specifically: 1.      Is the exposure value defined in Article 111 the correct basis for determining the portion of exposure exceeding the lien amount? 2.      Should the ETV ratio be calculated only up to the nominal amount of the lien, or on the full loan amount? 3.      When a loan is secured by multiple properties, should the ETV be calculated as a single ratio using the aggregate property value, or should separate ETVs be calculated per lien/property? 4.      How should the gross exposure be adjusted when multiple first-ranking liens exist, some held by the institution and others by third parties? 5.      In syndicated loans where liens are shared pari passu among institutions, how should the exposure be compared to the nominal amount of the lien for risk weighting under Article 124(1)? 6.      In cases where the lien sequence is broken (e.g., junior liens held by third parties), is it permissible to distribute the property value across liens to optimise ETV ratios? 7.      Can an institution apply both the loan-splitting and ETV approaches to different parts of a single loan secured by multiple properties with varying characteristics (e.g., residential vs commercial)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7422
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

Clarification on Risk Weight Assignment for ADC Exposures in Default

Could you please clarify what risk weight should be applied to ADC exposures that are in default?

  • 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_7419
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 21/05/2025

Risk Weights for International Organisations under the Standardised Approach

Is it permissible that exposures to NATO Communication and Information Agency are assigned a 0 % risk weight under Article 118(f) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7411
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 18/07/2025

Application of real estate valuation principles to AIRB

Are the valuation principles per CRR 229.1(e) (capping to 6/8-year averages) applicable when using own estimates of LGD (AIRB)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7405
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 02/09/2025

Instructions for Row 0080 COREP template C 07.00

Should contractual arrangements that meet all of the conditions set out in Article 5, points (10)(a) to (e) of the CRR, be reported in the row 0800 of the template C 07.00?

  • 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_7402
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 19/09/2025

Interaction between CRR3 article 124 and article 193

When should an IPRE exposure be riskweighted at 150% according to CRR3 article 124 para 1 (b)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7401
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

Maturity floor for SFT transactions under a master netting agreement that does not fulfill the enforceability criteria of CRR Article 206.

Does the EBA recognise that Securities Financing Transactions (SFT) conducted under an industry master netting agreement (MNA) such as GMRA or GMSLA could be subject to the 5-day floor maturity under CRR Article 162(2)(d) to the extend such MNA (i) meets the requirements of CRR Article 207 (2) to (4) on the eligibility of the collateral but (ii) does not necessarily fulfill the close-out netting enforceability criteria of Article 206 due to local law and absence of robust netting legislation for instance? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7397
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 01/08/2025

Calculation of minimum lease payments in case of operational lease

Does the EBA acknowledge that the residual value should be discounted, or the interests on this residual value should be filtered out of the calculation of the discounted minimum lease payments, to avoid an increase of the exposure beyond the accounting value?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7393
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 21/05/2025

AIRB combined with Financial Collateral Comprehensive Method

Article 223 para 4 subpara (b) indicates that banks using the A-IRB approach can also utilize the Financial Collateral Comprehensive Method (FCCM). Does the EBA agree with this?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7382
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 31/10/2025

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:
  • Published as final Q&A: 24/10/2025

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:
  • Published as final Q&A: 31/10/2025

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

Identification of the part of the exposure not covered by the lien on the property

To identify the part of a non-ADC-exposure that shall be treated as stated in Article 124(1), which amount of the exposure has to be compared to the nominal amount of the lien?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7311
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/10/2025