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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

Particular wording used in Articles 45h(5)

Is the meaning of the wording used in Articles 45h(5), second subparagraph of Directive 2014/59/EU (BRRD) ("the resolution authorities responsible for subsidiaries on an individual basis") the same as the wording "resolution authorities of the subsidiaries" used in other articles of BRRD?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3208
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 21/01/2022

Eligible liabilities for the purpose of MREL

Can only eligible liabilities counting towards MREL be bailed in?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3207
  • Topic: MREL
  • Date of submission:

Interpretation of points (a) and (b) of Article 45a(1)

Do points (a) and (b) of Article 45a(1) state conditions for exemption from the MREL requirement for mortgage credit institutions financed by covered bonds? If so, how can resolution authorities verify these conditions beforehand?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3206
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 17/03/2017

Minimum requirements for own funds and eligible liabilities

Do all entities mentioned in Article 1(1) of Directive 2014/59/EU (BRRD) have to meet minimum requirements for own funds and eligible liabilities?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3205
  • Topic: MREL
  • Date of submission:
  • Published as final Q&A: 17/03/2017

Risk weight of EURATOM debt

Which risk weight shall apply to outstanding/new EURATOM debt instruments?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3204
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 14/07/2017

Definition of low default portfolios for 2017 supervisory benchmarking exercise: Missing Portfolio ID for exposures assigned to both the exposure class ‘institutions’ and to the sector of counterparty ‘general governments’

Which Portfolio ID should be used regarding the definition of low default portfolios (Annex I, C 102.00 Draft ITS) for exposures assigned to both(i) the exposure class ‘institutions’ in accordance with annex II, C 102.00, column 070 Draft ITS with reference to COREP and(ii) the sector of counterparty ‘general governments’ in accordance with annex II, C 102.00, column 080 Draft ITS with reference to FINREP?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2017_3201
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 24/03/2017

Annex I Template C101.00 - Sovereigns

Clarifications around which entities to include for those identified by a bloomberg ticker referencing a Sovereign

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2017_3197
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 26/07/2019

Market risk capital treatment for third country CIU positions

For the purposes of Article 349 (F), which third country legislation may be considered to be equivalent to Directive 2009/65/EC of the European Parliament and of the Council of 13 July 2009 on the coordination of laws, regulations and administrative provisions relating to undertakings for collective investment in transferable securities (UCITS)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3195
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Supervisory Benchmarking Exercise, Annex II, C 102.00, Columns 150-170 - NACE code, type of exposure, size of exposure

How should we report NACE code / Type of Exposure / Size of Exposure in template C 102.00 of Annex I?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2017_3194
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

[Supervisory Benchmarking Exercise] Annex II, C 102, Column 110 - Filling in for LDPs

How should we report collateralisation status for secured facilities and collateralised SFT and Derivatives activity?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2017_3193
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as Rejected Q&A: 11/02/2022

Supervisory Benchmarking Exercise, Annex II, C 102.00, Column 100 - Facilities

How should we classify exposures into the list of facility types provided in the templates?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2017_3192
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Supervisory Benchmarking Exercise, Annex II, C 102, columns 070 and 080 Counterparty types

What counterparty types should be included in the Low Default Portfolio exercise?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2017_3191
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 26/07/2019

Annex II, C 102.00, column 020 - Portfolio name

Please provide guidance on how to categorise entities as ‘Large Corporates’, ‘Large Corporate Sample’, ‘Institutions’ & ‘Central Banks’.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2017_3189
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Annex II, C 102.00, column 020 – Large corporate sample

How should we interpret ‘Large Corporate Sample’ category under Annex II, C 102.00 column 020?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2017_3188
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Annex I, template C 101.00 – Multiple entities mapped to the same LEI

Under LDP Counterparties list, multiple entities are mapped to the same LEI. What is the distinction between the two entities and how does this impact the way we report the exposures?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2017_3187
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Supervisory Benchmarking Portfolios (SBP) - Z axes on C 101.00 and C 102.00

Should the 'counterparty credit risk' and 'credit risk and free deliveries' Z axes on the C 101.00 and C 102.00 reports roll up into the 'credit risk, counterparty credit risk and free deliveries' Z axes on the same reports?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2017_3185
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Content of templates C 105.01, C 105.02 and C 105.03

As reporting corresponding to 2016 exercise (and to be submitted before 11 April 2017) is related just to LDP, templates C 105.01, C 105.02 and C 105.03 should include only models with scope of application LDP? That is, is it correct that models with scope of application related exclusively to HDP are not reported in templates C 105.01, C 105.02 and C 105.03 for this second submission?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2017_3184
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:

Template C 07.00, column 230: of which: with a credit assessment by a nominated ECAI

We would like to know that whether ECAI rated CRM will be considered to report this column.Case: Unrated Corporate customer pledges ECAI rated debt instruments. Will this exposure be reported in column 230?

  • 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: 2017_3183
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 04/08/2017

Validation rule v3950_s for nGAAP

For some Institution, which don't follow the IFRS recommendations respective interest income on liabilities and interest expense on assets it might happen,,that they show negative interest income. Because according to Austrian GAAP it it is allowed, that negative interest rates reduce interest income and might turn negative. So v3950_s can not be fulfilled in some cases and therefore v3950_s should be "non-blocking" for nGAAP reporters.

  • 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: 2017_3182
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/08/2017

Annex VI, template C 108.00, Definition of P&L

Is the definition of P&L, for template C108.00,(i) the P&L Vector generated using historically simulated daily market price/risk factor movements; ie. the underlying daily P&L distribution used to derive VaR; or(ii) instead, the actual P&L (adjusted for Theta, settled cash flows, etc)?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
  • ID: 2017_3175
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 24/03/2017