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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

Interaction of the risk drivers employed to define the structure of the PD model and the requirement to avoid the excessive cyclicality of own funds requirements.

Is considering the requirement of CRR Article 170 4(c) to incorporate the ‘delinquency’ risk driver in the structure of rating systems possible, to avoid a potential excessive cyclicality of own funds requirements via the use of appropriate calibration techniques in line with the Entity’s chosen calibration philosophy?

  • 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: 2024_7083
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 05/02/2025

Interaction of the structure of the rating system and homogeneity requirements with conservatism in the application of risk parameters

Considering a rating structure defined according to article 170 of CRR, would the consideration of conservatism in the application of risk parameters alter such structure? In particular, do homogeneity analyses need to be conducted before or after the consideration of the conservatism in the application of risk parameters described in section 8.1 of the EBA/GL/2017/16?

  • 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: 2024_7044
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 05/02/2025

Treatment of lease commitments from operate-lease contracts in supervisory reportings

Gemäß Art. 5 Abs. 1 CRR sind Risikopositionen als Aktivposten (Vermögenswert) oder außerbilanzieller Posten definiert. Bedeutet dies im Umkehrschluss, dass Leasingzusagen für Operate-Lease-Verträge nicht in den aufsichtsrechtlichen CRR-Meldungen auszuweisen sind, da diese nach nationalen Bilanzierungsregeln (HGB) nicht als außerbilanzieller Posten unter dem Bilanzstrich auszuweisen sind? According to Article 5 (1) CRR, risk positions are defined as an asset or off-balance sheet item. Conversely, does this mean that lease commitments for operate-lease contracts are not to be shown in supervisory CRR reportings, as these are not to be reported as off-balance sheet items below the balance sheet line under national accounting rules (HGB)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7101
  • Topic: Supervisory reporting
  • Date of submission:
  • Published as Rejected Q&A: 05/02/2025

Failed rule EGDQ_0875 – proposed check on 12/2023 FP

How to cope with the issue described below for the future EBA Funding Plan deliveries avoiding any “failed” rule?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
  • ID: 2024_7156
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as Rejected Q&A: 31/01/2025

Funding plan - validation rule EBA_v08993

How can we solve a breach in the v08993_m rule, when the items compared between the Funding plan template P01.02 and the FINREP F08.01 template are not compatible ? Indeed, the liabilities to be declared in P01.02 in line r145 are supposed to exclude those held for sale, but their amount is compared to the FINREP amount that includes the portion held for trading.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
  • ID: 2024_7134
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as Rejected Q&A: 31/01/2025

Funding plan - validation rule EBA_v08992

How can we solve a breach in the v08992_m rule, when the items compared between the Funding plan template P01.02 and the FINREP F08.01 template are not compatible ? Indeed, the liabilities  to be declared in P01.02 in line r140 are supposed to exclude those held for sale, but their amount is compared to the FINREP amount that includes the portion held for trading.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
  • ID: 2024_7133
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as Rejected Q&A: 31/01/2025

Funding plan - validation rule EBA_v08991

How can we solve a breach in the v08991_m rule, when the items compared between the Funding plan template P01.02 and the FINREP F08.01 template are not compatible ? Indeed, the deposits to be declared in P01.02 in line r130 are supposed to exclude those held for sale, but their amount is compared to the FINREP amount that includes the portion held for trading.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
  • ID: 2024_7132
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as Rejected Q&A: 31/01/2025

Funding plan validation rule EBA_v08990

How can we solve a breach in the v08990_m rule, when the items compared between the Funding plan template P01.02 and the FINREP F08.01 template are not compatible ? Indeed, the deposits from non-financial corporations to be declared in P01.02 in line r060 are supposed to exclude those held for sale, but their amount is compared to the FINREP amount that includes the portion held for trading.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
  • ID: 2024_7131
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as Rejected Q&A: 31/01/2025

validation rule EBA_v08988

How can we solve a breach in the v08988_m rule, when the items compared between the Funding plan template P01.02 and the FINREP F08.01 template are not compatible ? Indeed, the repurchase agreements  to be declared in P01.02 in line r010 are supposed to exclude those held for sale, but their amount is compared to the FINREP amount that includes the portion held for trading.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/04 - Guidelines on harmonised definitions and templates for funding plans of credit institutions - repealed by EBA/GL/2019/05
  • ID: 2024_7130
  • Topic: Supervisory reporting - Funding Plans
  • Date of submission:
  • Published as Rejected Q&A: 31/01/2025

EBA_v10862 (Type – Warning validation): Assets under custody ({G01.00,r0060,c0010}) should be equal to the value in FINREP ({F22.02,r0060,c0010}).

The “Custody assets” referred in FINREP 22.2 is described as “services of safekeeping and administration of financial instruments for the account of clients provided by the institution and services related to custodianship such as cash and collateral management”.  How should the word “Services” in the above definition be interpreted?  Does it mean to populate a balance only in those cases where some fee is being charged for services provided or record all custody assets irrespective of any fee that is charged or revenue being generated? Extract from Annex V 21.2. Assets involved in the services provided (22.2)285. Business related to asset management, custody functions, and other services provided by the institution shall be reported using the following definitions:  (a) ‘Asset management’ shall refer to assets belonging directly to the customers, for which the institution is providing management. ‘Asset management’ shall be reported by type of customer: collective investment undertakings, pension funds, customer portfolios managed on a discretionary basis, and other investment vehicles;  (b) ‘Custody assets’ shall refer to the services of safekeeping and administration of financial instruments for the account of clients provided by the institution and services related to custodianship such as cash and collateral management. ‘Custody assets’ shall be reported by type of customers for which the institution is holding the assets distinguishing between collective investment undertakings and others. The item ‘of which: entrusted to other entities’ shall refer to the amount of assets included in custody assets for which the institution has given the effective custody to other entities;   As the validation rule “V10862" matches 2 data points (AUM and Custody assets) which in GSII is reported in one cell under table G01.00 Row 0060 “Assets under Custody” whereas in FINREP table 22.2 there are two different cells representing it “Assets Management(by type of customer) Row 0010” & “Custody assets (by type of customer) Row 0060” , thus making the validation incorrect? Hence, please clarify as to how to interpret the validation and whether it will be updated to include Asset Management and Custody Assets in FINREP 22.2 (i.e. validation will be Asset Management + Custody Assets in FINREP 22.2 to "Assets Under Custody" in GSIB) such that the number then reported will tie back with GSIB "Assets under custody”.

  • 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 (repealed)
  • ID: 2024_7122
  • Topic: Supervisory reporting - Other
  • Date of submission:
  • Published as Rejected Q&A: 31/01/2025

Supervisory delta for commodities with negative prices

Article 279a (1), (a) of the CRR establishes the formula to be used for calculating the supervisory delta of options mapped to all risk categories except for the interest rate category. Can such formula be made compatible with market conditions in which commodities may have negative prices?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5747
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 31/01/2025

Application of the formula for the determination of the risk weight for a specific vega risk factor k

Is it permitted to use the formula proposed in the original Basel text (MAR 21.92) to calculate the risk weight for a specific vega risk factor k, in deviation from Article 325ax Paragraph 3 CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5635
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 31/01/2025

Fair value adjustments that arise as a result of applying fair value hedge accounting

This question is a reformulation of the Q&A 4406, with two examples for clarify the problem and some possible answers. Should fair value adjustments which arise as a result of applying fair value hedge accounting to mitigate interest rate risk be treated under the CRR credit risk framework or under a different risk framework? And if under a different risk framework, which risk framework should that be?

  • 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 (repealed)
  • ID: 2023_6930
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 24/01/2025

Definition of financial institution under Article 4(1)(26)

Does the definition of financial institution under Article 4(1)(26) CRR include trust companies under Liechtenstein law?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7300
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 21/01/2025

Definition of ancillary services undertaking under Article 4(1)(18)

Does the definition of ancillary services undertaking under Article 4(1)(18) CRR include trust companies under Liechtenstein law?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7299
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 21/01/2025

Trade exposures to Qualifying Central Counterparties and collateral substitution

In case the original exposure is fully exempt from the application of the large exposure limit based on Art. 400 (1) (j) CRR as a trade exposure to a QCCP, no calculation of an exposure “after taking into account the effect of the credit risk mitigation in accordance with Articles 399 to 403” for purposes of the large exposure limit pursuant to Art. 395 (1) CRR takes place. Is accordingly a substitution of an exposure amount to the issuer of a security not required when the trade exposure to the QCCP is collateralised with the security, as the original exposure is fully exempt from the large exposure limit?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7268
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 21/01/2025

Definition of Stable Deposits in C73 Outflows

Can the EBA confirm, where customers who qualify for Transactional treatment under LCR delegated act, Article 24 1.b (ie are not captured by Article 25 Higher Outflows), with deposits held in a transactional account, ie a current account, but fail the activity criteria for Transactional accounts per Article 24 para 3 (salaries, income or transactions are regularly credited and debited respectively against that account), however pass the criteria for Established customer relationship (ie relationship >1 year), can these be treated as Stable with a 5% weighting?  Or Other with 10% weighting?

  • 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: 2024_7125
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 21/01/2025

LCR Treatment of Cancelled Term Deposit with Non-Financial Customers

Should time deposits from non-financial customers, which have been cancelled and fall due within 30 days, be multiplied by 40% as per Delegated Regulation 2015/61 Article 28(1)? Assuming these deposits don't meet the criteria for Delegated Regulation 2015/61 Article 27. This seems to provide a favorable treatment for time deposits which have been cancelled and fall within 30 days for non-financial customers (40%), where as those for retail and financial customers would be multiplied by 100% outflow rate. 

  • 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: 2024_7104
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 21/01/2025

Reporting framework 4.0 Validation rules release (new format) (Uploaded on 19/12/2024)

In light of the validation rules release (new format) published on 19 December 2024 on your website, we have identified potential issues with the following validations: Validation v0329_m: This rule checks that the value in COREP template C_07.00.a, column 0220, equals the sum of columns 0215, 0216, and 0217. However, the ITS stipulates that column 0215 reflects values before currency mismatch, columns 0216 and 0217 represent adjustments for supporting factors, and only column 0220 should account for currency mismatch adjustments. The validation v0329_m appears to disregard the intended adjustment logic for currency mismatch, making the rule inconsistent with the ITS requirements. Validation v0407_m: This rule checks that the value in COREP template C_09.01.a, column 0090, equals the sum of columns 0080, 0081, and 0082. The ITS specifies that columns 0080–0090 in C_09.01.a should correspond directly to columns 0215–0220 in C_07.00.a. Given that column 0220 in C_07.00.a includes adjustments for currency mismatch, the requirement for column 0090 to equal the sum of columns 0080, 0081, and 0082 is contradictory to the ITS logic. Based on these observations, we believe that both validations, v0329_m and v0407_m, are incorrect. We kindly request your confirmation and guidance on this matter, including any planned revisions to these validations.  

  • 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 (repealed)
  • ID: 2024_7289
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2025

C14.00 - v7364_m - Type of Assets (column 0160)

According to EBA Q&A 2023_6864 the validation rule v7364_m is not in line with the current regulatory provisions and shall be deleted. However, in the latest revised list of ITS validation rules as per September 2024 the rule is still active. Could you please amend the validation rules and deactivate the rule as per the above mentioned Q&A.

  • 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 (repealed)
  • ID: 2024_7287
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2025