Article 111(2) states, that the exposure value of an off-balance-sheet item listed in bucket 5 of Annex I of CRR shall be calculated by multiplying the item’s nominal value after the deduction of specific credit risk adjustments in accordance with Article 110 and amounts deducted in accordance with Article 36(1) point (m) by 10 %.

Bucket 5 of Annex I of CRR contains the following items (a) to (c):

• the undrawn amount of unconditionally cancellable commitments (item listed in point (a))
• 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))
• 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))

Article 495d(1) states, that, by way of derogation from Article 111(2), the exposure value of off-balance sheet items in the form of unconditionally cancellable commitments shall be calculated by multiplying the result of the beforementioned calculation described in Article 111(2) by the following percentages:

• 0 % in the years 2025 to 2029
• 25 % in the year 2030
• 50 % in the year 2031
• 75 % in the year 2032

To us it is not clear, if Article 495d(1) refers to all commitments given which may be cancelled by the institution unconditionally and without prior notice within the boundaries of the national legislation applicable and of legal acts regarding customer protection, where applicable, or if it refers specifically only to items related to point (a) of bucket 5 of Annex I of CRR and would hence not be applicable to items related to points (b) and (c) of bucket 5.