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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.

List of Q&A's

Controls v90304_ and v903265_s

Why does the v90304_m control check that line 020 is equal to the sum of lines 030 and 070 because normally line 020 should be equal to line 030 minus line 070 as indicated in the document "annex_1_solvency_-_crr3_-_phase_1_-_op_risk_tc.xlsx" of your publication of 20/02/2024 (The EBA consults on amendments to the operational risk Pillar 3 and supervisory reporting requirements to implement the Basel III reforms in the EU | European Banking Authority) ? Why does the v903265_s control check that line 020 must be greater than or equal to 0 because the net income could be negative ?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Value accepted for ID Code of the Type of the instrument is no longer in line with regulator's requirement

Since last update of Invoke, the value accpeted for colomn FC0101 of the template FC.01 is the following closed list of choices: Banking sector; Insurance sector, Investments services sector and Other undertaking of the groupe. However, according to regulation (EU) 2022/2454, this column is related to ID code type of the instrument and the following is instructed : Type of ID code used for the ‘ID code of the instrument’ item. One of the options in the following closed list of codes shall be used: 1 -ISO 6166 for ISIN code 2 -CUSIP (the Committee on Uniform Securities Identification Procedures number allocated by the CUSIP Service Bureau for United States and Canadian companies) 3 -SEDOL (Stock Exchange Daily Official List for the London Stock Exchange) 4 -WKN (Wertpapier-Kennnummer, the alphanumeric German identification number) 5 -Bloomberg Ticker (Bloomberg letters code that identifies a company’s securities) 6 -BBGID (the Bloomberg Global ID) 7 -Reuters RIC (Reuters instrument code) 8 -FIGI (Financial Instrument Global Identifier) 9 -other code provided by members of the Association of National Numbering Agencies 99 –A code allocated by the undertaking.

  • Legal act: Directive 2002/87/EC (FiCOD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2454 – ITS on the reporting of intra-group transactions and risk concentration for financial conglomerates

Disclosure of liquidity requirements - NSFR - LIQ2. Number of quarters to be disclosed in the Disclosure Period

In Q&A 2025_7533, EBA has confirmed that "for half-year disclosures, two data templates representing the first (Q1) and the second quarter (Q2) of the current disclosure year" are required to be disclosed in disclosure template EU_LIQ2. However, according to EBA DPM (20260106 Annotated Table Layout  PILLAR3 4.2 CODISPILLAR3 4.2), there is a dependency between reporting periods reported in EU_KM1 (K_61) and those reported in EU_LIQ2 (K_74). Specifically, EU_KM1 (K_61) requires more than two reporting periods. As a result, it is not possible to report only two periods in EU_LIQ2, as suggested in Q&A 2025_7533, without violating the predefined DPM rules.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Validity of validation rule v903610

Validation rule v4786 seems invalid. with {tC_09.02, (r0010, r0020, r0030, r0050, r0060, r0070, r0080, r0090, r0100, r0110, r0120, r0130), default: 0, interval: true}: {c0105} >= {c0110} This formula  implies that RW can never be higher than 100% which is incorrect

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Incoherent formulae on the validation rule v0478_m

Should the validation rule v0478_m be active?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

sign validation rules J_03.00 - BREAKDOWN OF SENSITIVITY ESTIMATES - IRRBB

Why are validation rules v23169_s and v23171_s implemented?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Determine the pass-through rate for "standardized approach"

Our Bank as another non-listed institution, as part of the CRR Regulation, is required to apply the "standardized approach" for interest rate risk, as defined in Regulation 2024/857. Banks subject to the simplified standardized methodology apply, by way of derogation from Article 8(9), the pass-through rate specified in point 5(a), 5(b), and 5(c) of the Annex. Our Bank, as another non-listed institution, should independently calculate the pass-through rate, taking into account the Bank's historical data for the base scenario and scenarios predicting a decrease and an increase in short-term interest rates. Currently, the Bank applies the pass-through rate from points 5a, 5b, and 5c of the Annex to the Regulation. Since the UKNF has issued a recommendation that the Bank independently determine the pass-through rate, please provide the methodology for calculating the scenarios referred to in Article 25(2), (3), and (4), as well as point 5(a), (b), and (c) of the Annex to the Regulation.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2023/08 - Guidelines on the benchmarking of diversity practices, including diversity policies and gender pay gap

Incoherent formulae on the control v23086_m

Could you please confirm that the formulae of the control v23086_m needs to be modified?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Incoherent formulae on the validation rule v23087_m

Could you please confirm that the formulae of the control v23087_m needs to be modified?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

FICOD Inconsistency between ITS and Taxonomy

Dear all,    I'm contacting you as we are working in the implentation of FICOD DPM 4.2 framework and we have some difficulties to understand the technical expectations regardings : L_0100 : column 0101 L_0200 : column 0101 L_0200 : column 0201 Those three cells seem to point on a list of closed options called [ZZ:ZZ94], which can take : x840 banking sector x841 insurance sector x842 investments services sector x843 other undertaking of the group We do not understand this modelisation as for us those columns should be pointing on the following values : ype of ID code used for the ‘ID code of the instrument’ item. One of the options in the following closed list of codes shall be used: 1 - ISO 6166 for ISIN code 2 - CUSIP (the Committee on Uniform Securities Identification Procedures number allocated by the CUSIP Service Bureau for United States and Canadian companies) 3 - SEDOL (Stock Exchange Daily Official List for the London Stock Exchange) 4 - WKN (Wertpapier-Kennnummer, the alphanumeric German identification number) 5 - Bloomberg Ticker (Bloomberg letters code that identifies a company’s securities) 6 - BBGID (the Bloomberg Global ID) 7 - Reuters RIC (Reuters instrument code) 8 - FIGI (Financial Instrument Global Identifier) 9 - other code provided by members of the Association of National Numbering Agencies 99 – A code allocated by the undertaking Please refers to the ITS : Implementing regulation - 2022/2454 - EN - EUR-Lex We do not understand the expections from EBA and we strongly think that the value published on those cells does not refer to the correct choice list. Could you please advises us on a workaound?

  • Legal act: Directive 2002/87/EC (FiCOD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Clarification on reporting of columns 0050–0100 in template J 09.02b (EGDQ_0902b) – delta cashflows vs repricing dates

Could the EBA please confirm the supervisory expectation regarding the correct population of columns 0050–0100 in template J 09.02b? Specifically, should these columns be reported as:(a) delta cashflows / changes relative to the baseline, consistent with the reference to J 01.00 r0040; or (b) repricing dates (in years) of deposits under each of the six SOT scenarios, consistent with the validation rules applied? If repricing dates are intended, we would appreciate clarification on how this aligns with the explicit reference to J 01.00 r0040 and the definition of “Δ EVE” in the ITS.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Are the validation rules v10667_m, v4769_m, v4772_m, v903250_h correct?

The  validation rules v10667_m, v4769_m, v4772_m, v903250_h included in DPM 4.2 appear incorrect. v10667_m: The rule requires that the exposure-weighted maturity values (c0250) multiplied by Exposure value (c0110) in templates c08.01 and c08.02 are equal. However, as the Maturity is required to be rounded to full days and cannot be delivered with decimals, the rule cannot be met as the rounding will cause a difference between the templates. v4769_m: The rule requires that the total of all exposure classes equals the sum of the exposure classes for template C08.01. However it is incorrectly applied to columns that contain exposure-weighted non-monetary values (c0230-0240: %s, c0250: days), which cannot be aggregated. v903250_h: The rule requires that the absolute value of r0010 is greater that sum of  absolute values on rows r0015 and r0016 in template C08.01. However it is incorrectly applied to columns that contain exposure-weighted non-monetary values (c0230-0240: %s, c0250: days), which cannot be aggregated. v4772_m: The rule requires that the Expected Loss amount (c0280) is smaller than the Original Exposure Value (c0020). This rule appears incorrect as the c280 is reported after substitution effects CRM, where are c0020 is reported prior to substitution effects due to CRM.  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Validation rule v903627_h

Is the validation rule v903627_h consistent ? Indeed an equality is expected between row Corporates {r0030} and the sum of rows SME {r0050} and Large Corporates {r0051} which is not possible as it doesn't take into account the whole corporates scope.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Incoherent formulae on the validation rule v4769_m

Should the validation rule v4769_m apply to columns 0230, 0240, and 0250 of report C08.01?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

C.08.01 - VariableVID 3293070 - Identical cells

Should the identical cell rule with VariableVID equal to 3293070 be applicable to C08.01?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Incoherent formulae on the validation rule v0476_m

Should the validation rule v0476_m be active?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Incoherent formulae on the validation rule v0471_m

Should the validation rule v0471_m be active?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Incoherent formulae on the validation rule v0473_m

Should the validation rule v0473_m be active?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Incoherent formulae on the validation rule v0475_m

Should the validation rule v0475_m be active?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions

Incoherent formulae of the validation rule v1674_m

Should the validation rule v1674_m be active?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions