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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.

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List of Q&A's

Clarification on summing columns in Template 10 "Other climate change mitigating actions that are not covered in the EU Taxonomy"

We ask for clarification whether 'columns d' and 'e' in Template 10 (respectively 'Type of risk mitigated (Climate change transition risk) ' and 'Type of risk mitigated (Climate change physical risk) ') should add up to 'column c' ('Gross carrying amount (million EUR) ')?

  • 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: 2022_6564
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 25/11/2022

When to apply CCF to residential mortgage off balance sheet exposure

For off balance sheet exposures, when Article 125(2)(d) references 'the part of the loan' that is less than or greater than 80% of the property value, does this refer to exposure, or gross loan balances. Therefore, should the required CCF be applied before or after comparing the balance commitment to the property value?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6563
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/11/2022

Applicable remuneration policy

The question relates to members of staff who are classified as identified staff by the group, whose country of employment is a third country, and who are also appointed as non-executive directors (“NEDs”) on the board of directors of a subsidiary credit institution licensed in a Member State (“EU subsidiary”). These NEDs are classified as identified staff for the EU subsidiary but are not seconded to the EU subsidiary and are not paid any form of remuneration or emolument for their directorship on the EU subsidiary. In such case, should the remuneration policy of the EU subsidiary apply to such NEDs even if they do not receive any form of compensation/benefit whatsoever for their role with the EU subsidiary? Whilst in relation to seconded individuals this matter has been clarified in the EBA GLs on sound remuneration policies (EBA/GL/2021/04), it is still not expressly clear whether any such NEDs would also be subject to the EU subsidiary’s remuneration policy. In this case it is reasonably expected that given that such NEDs are not being paid either directly or indirectly for the services they are rendering to the EU subsidiary, the group’s remuneration policy (rather than the EU subsidiary’s remuneration policy) is to apply. It would be appreciated if this point is clarified.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6562
  • Topic: Remuneration
  • Date of submission:
  • Published as Rejected Q&A: 07/09/2022

Financial guarantees received reported in F 09.02

Should financial guarantees received be reported in template F 09.02 with their nominal amount (as it is explicitly noted for the financial guarantees given in paragraph 118, Part 2 of Annex V to Regulation (EU) 2021/451 (ITS) or the maximum amount that can be considered is the maximum amount the counterparty would have to pay if the guarantee is called on as of the specific reporting date?

  • 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: 2022_6561
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 10/03/2023

Pillar 3 disclosure on Net Stable Funding Ratio

How should NSFR LIQ2 table for Pillar 3 disclosure be compiled with respect to amounts reported in NSFR regulatory template C80 rows 0040, 0050 and 0060 for the non-HQLA part (i.e., 0010, 0020, 0030, respectively weighted by applicable weights reported in columns 0090, 0100, 0110). Those items seem to be not included in any of the weighted RSF items/components of LIQ2.

  • 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: 2022_6560
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 30/01/2023

Wrong validation at the level of the number of obligors between C08.01 and C34.07.

  May we kindly ask you to disable validation rules v10523_h and v10524_h? These checks are not correct. This item is closely linked to a previous Q&A with the ID 2021_6202, we can however not find this Q&A on the EBA site.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6559
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2022

Traditional SRT securitisations with derecognized underlying assets

According to the instructions included in Regulation (EU) 2020/429, the column 0210 of C 14.00 shall show the following: “…Value adjustments shall include any amount recognized in profit or loss for credit losses of financial assets since their initial recognition in the balance sheet.” Additionally, based on Q&A 5077, where an inconsistency in validation rule v4797_m in template C 14.00 is raised, the provisions reported in column 0210 are referred to outstanding nominal amount at the reporting date. How should column 0210 be filled in case of traditional SRT securitisations, where the underlying assets are entirely derecognized and for which no provisions are recognized in balance sheet after the origination?

  • 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: 2022_6558
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 29/06/2023

Treatment of Security Lending and Borrowing Transactions for LCR purposes

How should Security Lending and Security Borrowing Transactions be reported in the LCR template, considering the changes introduced by the Commission Delegated Regulation (EU) 2022/786 about Security Financing Transactions? In detail, shall Security Lending and Borrowing transactions be reported as collateral swaps in C 75.00 template or shall they be reported as Security Financing Transactions in C 73.00 and C 74.00?

  • 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: 2022_6557
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 26/05/2023

COREP C35 - consistency controls v09703_m and v09711_m

The control claims that for C35.01 row r0070 should be the sum of row r0080-r0100 of C35.02 and row r0070 and row r0120 of C35.03. Should this control be applicable?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6556
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 31/01/2023

COREP C35 - consistency controls v09683_m; v09684_m and v09691_m

The control claims that for C35.01 row r0050 should sum row r0060 of C35.02 and row r0050 of C35.03. Should this control be applicable?

  • 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: 2022_6555
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 31/01/2023

COREP C 35 - consistency controls among C 35.01, C 35.02 and C 35.03

Should the following controls: v09692_m; v09699_m; v09683_m; v09684_m; v09691_m; v09703_m and v09711_m be applicable?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6554
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 10/03/2023

C 08.01, v10540_h

The validation rule claims that the sum of rows 0040, 0050 and 0060 of column 300 of template C 08.01 should equal the value reported in C 34.07, row 180, column 030. Is this validation rule applicable?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6553
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2022

CRE loans versus Loans collateralised by commercial immovable

The question concerns the classification of commercial real estate (CRE) loans and loans collateralised by CRE in template F 18.02 of FINREP. It is not clear whether the two loan categories are mutually exclusive or whether it is possible that a loan can be classified both as a CRE loan and as a loan collateralised by CRE.

  • 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: 2022_6552
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 31/03/2023

Identification of counterparty

The treatment of client exposures to a CCP via a clearing member is described in art 305 and consists of 1/ application of art 305 paragraph 1 (when the conditions in paragraph 2 are not met) = use of counterpart credit risk section 1 to 8 for the CCP-related transactions with the clearing member 2/ application of art 305 paragraph 2 (and subject to paragraph 3) = use of art 306 for the trade exposures with the CCP Can it be clarrified which party should be treated as the counterparty in sush a transaction (the clearing member or the CCP) under Corep? Can it in addition be clarrified whether the same counterparty as in Corep should be used under Finrep?    

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6551
  • Topic: Market infrastructures
  • Date of submission:
  • Published as Rejected Q&A: 28/03/2023

Promotional loans that constitute claims on central governments, regional governments, local authorities or public sector entities

As per article 429a (1), paragraph (d) of CRR, only claims on central governments, regional governments, local authorities or public sector entities in relation to public sector investments and promotional loans are exempt from Leverage ratio exposure where the institution is a public development credit institution, the exposures arising from assets that constitute claims on central governments, regional governments, local authorities or public sector entities in relation to public sector investments and promotional loans. In C40 report, ITS mentions that this part of the reporting collects data on an alternative treatment of derivatives, SFTs, off-balance sheet items, exempted public sector investments and exempted exposures to promotional loans. In C40 report also only exempted exposures to promotional loans are to be reported. That is claims on central governments, regional governments, local authorities or public sector entities only are to be reported in C40 report also. Row 0350 of C40 report requirement Promotional loans - Claims on non-financial corporations - Accounting balance sheet value Where the institution is a public development credit institution, the accounting balance sheet value under the applicable accounting framework of assets that constitute claims on non-financial corporations in relation to promotional loans Row 0360 of C40 report requirement Promotional loans - Claims on households - Accounting balance sheet value Where the institution is a public development credit institution, the accounting balance sheet value under the applicable accounting framework of assets that constitute claims on households in relation to promotional loans  As the only exposures to promotional exempt are to be reported in C40 also. However these two rows 0350 and 0360 of C40 report requirements are not in cosistence with the article 429a (1) (d) and (e) also. Please clarify.

  • 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: 2022_6550
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as Rejected Q&A: 18/04/2023

v5839_m vs Q&A 5434

When will the validation rule v5839_m reflect changes recommended in Q&A 5434 of the Single Rulebook Q&As?

  • 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: 2022_6549
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2022

Securitised derecognised assets

Template C 14.00 (SEC DETAILS), column 0210, requires reporting of information on securitised exposures including associated provisions. The memorandum item on the standardised calculation in C 14.01 (SEC DETAILS APPROACH), column 0448 also requires provisions on underlying asset as an input. What provisions should be used when the securitised exposures are also derecognised by the reporting entity from an accounting perspective?

  • 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: 2022_6548
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 13/10/2023

ITS ESG P3 - Non-financial risks and value chain

1. Should entities report their own non-financial risks arising from its own operations, or only the non-financial risks related to the operations of its counterparts and customers? 2. If “counterparts” includes the latter then; what is the definition of a “counterpart” ? Does it include the third party value chain e.g. suppliers and outsourcing agreements?

  • 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: 2022_6544
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 17/02/2023

v6303_m not passed due to market conditions (C 24.00)

Because of the evolutions of the rates, the ratio SVaR/HVaR has dropped such that the SVaR is below the HVaR. In coordination with the local supervisor, we compensate this RWEA underestimation by applying a self-imposed RWA add-on through the application of Article 3 CRR. However, when we report the information of template C 24.00, the validation rule v6303_m blocks the submission because it enforces the following rule v6303_m: [C 24.00 (r0010)] {c0060} >= {c0040} We request de-activation of this rule so that our report can be submitted.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1423/2013 - ITS on disclosure of own funds requirements
  • ID: 2022_6543
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2022

Template 5: Banking book - Climate change physical risk: Exposures subject to physical risks

What is the relation between row 1-9 and 10-12? Are rows 10-12 based on the sectors mentioned in 1-9 only, or based on all sectors (including the ones not mentioned in 1-9)?

  • 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: 2022_6541
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 25/11/2022