- Question ID
-
2025_7637
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Supervisory reporting - FINREP (incl. FB&NPE)
- Article
-
128
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions
- Article/Paragraph
-
Annex V (FinRep) - Part 2 (45)
- Type of submitter
-
Credit institution
- Subject matter
-
Definition of Subordinated Debt holdings in Finrep vs COREP under CRR3
- Question
-
Could you please confirm whether, following the implementation of Regulation (EU) 2024/1623 of the European Parliament and of the Council amending Regulation (EU) No 575/2013 (Capital Requirements Regulation 3 – CRR3), institutions will be required to report subordinated debt holdings differently in FINREP and COREP.
- Background on the question
-
Under Fin Rep the definition of subordinated assets includes any asset which is not highest in the order of priority. [Para 45 refers to a detailed definition in para 54: “Subordinated debt” instruments provide a subsidiary claim on the issuing institution that can only be exercised after all claims with a higher status have been satisfied”].
CRR3 introduces the concept of subordinated debt exposures under Article 128. This classification is prudential, based on eligibility for resolution/MREL purposes, and does not strictly follow legal ranking in insolvency.
For example, a bond flagged as senior but treated as subordinated for CRR3 purposes would remain senior in FINREP unless its prospectus includes contractual subordination clauses.
- Submission date
- Rejected publishing date
-
- Rationale for rejection
-
This Q&A has been rejected because answering it may pre-empt policy work currently in progress on Level 2 and 3.
- Status
-
Rejected question
