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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

Chip and Signature cards and their inclusion in the remit of RTS Article 11

Is cardholder signature a strong method of authentication when transacting with card present?If so, is there a requirement to ensure that on Chip and Signature cards we step up to signature from contactless after 5 contactless /cumulative value of 150 euros?If a signature is not considered to be strong customer authentication (SCA), are chip and signature cards exempt from SCA requirements under Article 11 of the RTS on strong customer authentication and secure communication?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4342
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 09/04/2021

90 Day Access via Direct Access

Should any solution which involves direct access, whether as a strategic solution to PSD2, or in relation to the obligation to provide a fallback interface, ensure that Account Information Service Providers (AISPs) can access the interface in the same manner as the dedicated interface, specifically on an ongoing basis and for a maximum of 90 days once the customer has provided consent and authenticated using strong customer authentication (SCA)?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4339
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Trusted Beneficiaries

Article 13 of the RTS on strong customer authentication (SCA) and secure communication does not seem to restrict the use of trusted beneficiaries beside the fact that the payee must be in the list of trusted beneficiaries when initiating the payment transaction. Is it correct to conclude from this that the usage of trusted beneficiaries is not further restricted and can, therefore, also be implemented as a generic beneficiary approval step prior to every initiation of a payment transaction?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4338
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 09/04/2021

FINREP Locom valued debt instruments: Reporting of "Accumulated negative value adjustments on LOCOM assets - credit risk induced"

Could it be that the following validation rules 5319_m until v5331_m are not correct for LOCOM valuated debt instruments. Should  "Accumulated negative value adjustments on LOCOM assets - credit risk induced"  be reported under accumalated impairment and not under "Accumulated negative changes in fair value due to credit risk on non-performing exposures"?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4336
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Finrep Solo GAAP: The following validation rules v5476_m until v5489_m are missing the column"Accumulated negative value adjustments on LOCOM assets - credit risk induced"

Dear Could it be that the the column "Accumulated negative value adjustments on LOCOM assets - credit risk induced" is missing in the validation rules from v5476_m until v5489_m?

  • 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: 2018_4335
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Mark-to-Market Method: remaining maturity for early-termination clauses (ETC)

For the purpose of determining the percentage applicable under the Mark-to-Market Method according to Article 274(2) or (3) CRR, how should the residual maturity be determined for contracts with an early-termination clause?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4329
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 07/05/2021

Exposures in the form of covered bonds

Would the preferential treatment set out in Articles 129(4) and (5) and in Article 161(1)(d) be applicable to derivative instruments entered into in relation to covered bonds exposures, provided that the counterparty’s claims are secured by the same pool of assets as the covered bonds’ and rank pari passu with the claims of the covered bonds holders?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4328
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 29/03/2019

ABCP Programme

Does an ABCP programme meet the definition under Article 242(9) of Regulation 575/2013 – or Article 242(11) CRR as amended by Regulation (EU) 2017/2401, which refers to-Article 2(7) in Regulation 2017/2402   when it invests not only in securitisation transactions (i.e. ABCP transaction as defined in Article 2(8) in Regulation 2017/2402) but also in other type of assets?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4324
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as final Q&A: 08/05/2020

ABCP programme

Does an ABCP programme meet the definition under Article 242(11) of Regulation (EU) No 575/2013 (CRR) as amended by Regulation (EU) 2017/2401 in any case, whether or not the credit risk of the financial assets acquired by the conduit is tranched into different risk categories at the programme level?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4323
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as final Q&A: 08/05/2020

Treatement of liquidity generated by the overnight maturity of Withdrawable Central Cank reserve in Counterbalancing Capacity panel of Template C66

How should “liquidity generated by the overnight maturity of withdrawable central bank reserve” be treated in Counterbalancing Capacity panel of Maturity Latter template C 66?

  • 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: 2018_4318
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:

Strong Authentication

Is one time passcode (OTP) Mail considered as a "Strong Customer Authentication" under Regulation (EU) 2018/389 – RTS on strong customer authentication and secure communication?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4315
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 15/01/2021

Definition of available cash for the purpose of determining intraday qualifying liquid resources in accordance with Regulation (EU) 2017/390 Art. 34(b)

For the purpose of determining intraday qualifying liquid resources according to Regulation (EU) 2017/390 Art. 34, to what extent does “available cash” mentioned in Art. 34(b) include balances on nostro accounts held “at one of the creditworthy financial institutions identified in Article 38(1)”?

  • Legal act: Regulation (EU) No 909/2014 (CSDR) - only RTS 2017/390
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2017/390 - RTS on prudential requirements of CSDs (CSDR-related)
  • ID: 2018_4312
  • Topic: Market infrastructures
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Definition of sponsor under Regulation (EU) No 2017/2402 (the Securitisation Regulation)

Does the definition of “sponsor” in the Securitisation Regulation include investment firms that are not located or established in the European Union?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4311
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Consent for the provision of PIS and AIS

Could the consent to Account Information Service Providers (AISP)/ Payment Initiation Service Provider (PISP) to provide services to a Payment Service User (PSU) also be revoked by the bank directly for PSU’s ease of use and could ASPSPs offer the PSU to generally “opt out” of being able to use the services of bank-independent Third Party Providers (TPPs)?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2018_4309
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 21/12/2018

Risk weight for new asset class of non-preferred senior debt

What risk weight should be applied to non-preferred senior (NPS) debt, under the standardised approach for credit risk?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4306
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Deduction of deferred tax assets that rely on future profitability

Is the deduction of the deferred tax assets that rely on future profitability (hereinafter, the “DTAs”) and the amount of the associated deferred tax liabilities (hereinafter, the “DTLs”) relevant for the calculation of the amount to be deducted from Common Equity Tier 1 (CET1) according to Article 36(1)(c) of Regulation (EU) No. 575/2013 (CRR) to be determined independently of the Accounting Policies defined by the Bank for the offsetting of the DTAs and the DTLs in the Balance Sheet and regardless of the way in which the DTAs and DTLs are reported in the Financial Statements?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4302
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 15/11/2019

Obligations stemming from "non-credit products"

To what extent do fees stemming from “non-credit products” fall under the notion of para 73 (a) of the EBA Guidelines on PD estimation, LGD estimation and the treatment of defaulted exposures?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/16 - Guidelines on PD estimation, LGD estimation and the treatment of defaulted exposures
  • ID: 2018_4301
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 07/05/2021

Immovable property collateral under the Standardised approach & Credit risk mitigation principles

Do the Article 193 ‘Principles for recognising the effect of credit risk mitigation techniques’ and Article 194 ‘Principles governing the eligibility of credit risk mitigation techniques’ apply to immovable property collateral under the Standardised approach?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4300
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 15/11/2019

Calculation of own funds required for payment institution in the Article 9 of Directive EU 2015/36 (PSD2) when "input funds" are credit transfers and "output funds" are direct debit

How to compute the “total amount of payment transactions executed” referred to in the calculation of “payment volume” for method B in the Article 9 of Directive EU 2015/36 (PSD2) when "input funds" on the payment account are credit transfers and "output funds" are direct debit?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4299
  • Topic: Authorisation and registration
  • Date of submission:
  • Published as final Q&A: 12/03/2021

Calculation of own funds required for payment institution in Article 9 of Directive EU 2015/36 (PSD2) when the payment institution offers acquiring services

How to compute the “total amount of payment transactions executed” referred to in the calculation of “payment volume” for method B in the Article 9 of Directive EU 2015/36 (PSD2) when the payment institution offers acquiring services?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4298
  • Topic: Authorisation and registration
  • Date of submission:
  • Published as final Q&A: 12/03/2021