Search for Q&As

Enquirers can use various factors to search for a Q&A:

These include searching by the Q&A ID; legal reference, date submitted, technical standard / guideline, or by keyword if known.
Searches can be extended to more than one legal act, topic, technical standard or guidelines by making multiple selections (i.e. pressing 'Ctrl' on your keyboard, and selecting the relevant ones from the drop-down lists by left mouse-click).

Disclaimer:

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.

Legal act

Topic

Article

COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations

Answer prepared by

Period posted start

Period posted end

Publication start

Publication end

Keywords

Question ID

Final Q&As Q&As under review Rejected Q&As Archived Q&As All Q&As

Export options

Select / deselect all results on this page

List of Q&A's

Template 3: Banking book - Indicators of potential climate change transition risk: Alignment metrics

Is it allowed to use another scenario than those prescribed by the IEA, as long as it is compatible with 1.5C trajectory and clearly documented in the narratives?

Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Misalignment between scope of reportable exposures against public authorities in template 7 ( CRR) and template 1 ( EU Taxonomy - acc to 2021/2178)

Should rows 280, 290 and 300 from Template 7 under ESG Disclosure only be limited to "Loans and advances" or should the scope of the rows be extended by including also debt security exposures (or other categories of exposures) in order to align with Annex V from European Commission published on 27.6.2023 , updating Section 1.2.1.4 from 2021/2178 ?

Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Template 2 – Total gross carrying amount reported in column A

Should column a be equal to sum (columns b to g + o)*(1- column p) as per XBRL validation rule?

Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Template 5 – Total gross carrying amount reported in column B

Which gross carrying amount should be reported in column b? Should it be the total of the exposures by sector as reported in Template 1 or should it be the total of columns c to f?

Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Alignment of the GAR Templates 7 and 8 with the templates used by the European Commission

According to the European Commission, in the COMMISSION DELEGATED REGULATION (EU) 2023/2486 of 27 June 2023, information on the six objectives must be reported. In addition, there are differences between the EC and Pillar 3 GAR templates, such as the absence of rows for financial corporations not subject to NFRD in Pillar 3, the presence of an "Of which adaptation" in column J, which is redundant as the objective in Pillar 3 is adaptation to climate change, and the presence of columns for the use of proceeds in the EC template, whereas the columns in Pillar 3 are for specialised lending. When will the Pillar 3 ESG reporting templates (6, 7, 8 and 9) be updated in line with those of the EC?

Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

ESG P3 - Templates 9.1 and 9.2 Decision Tree KPI BTAR for Financial Corporations

According to the question 2023_6681, the Financial Corporation located outside European Union (EU) and Financial Corporation located in EU but not subject to NFRD disclosures exposures should be reported in the row 44 of the template 7 Other assets (e.g. Goodwill, commodities etc.). In which row/group of rows should be reported in the Template 9.1 - Mitigating actions: Assets for the calculation of BTAR and Template 9.2 - BTAR Since there are only specific rows for Non-Financial Corporation?

Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

BTAR Disclosure Requirements

When does it become compulsory for banks to report the BTAR? When will the specifics on BTAR disclosure be published (i.e., what can be counted into BTAR etc.)?

Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Interpretation of ‘ The degree of correlation between the value of the assets relied upon for protection and the credit quality of the obligor shall not be too high.’

In Article 194, Quote Institutions may recognise funded credit protection in the calculation of the effect of credit risk mitigation only where the lending institution has the right to liquidate or retain, in a timely manner, the assets from which the protection derives in the event of the default, insolvency or bankruptcy — or other credit event set out in the transaction documentation — of the obligor and, where applicable, of the custodian holding the collateral. The degree of correlation between the value of the assets relied upon for protection and the credit quality of the obligor shall not be too high. Unquote My question is about the aforementioned correlation. If a obligor’s major asset is a very valuable mine asset, and the mine asset is collateralized by a bank as security for a loan, is it eligible for the bank to consider the value of the mine asset for calculating the ‘risk-weighted asset’? The value of the mine asset is valued by independent & renowned evalution agency and it meets with all other regulatory requirements for eligible collateral.

Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/09 - Guidelines on corrections to modified duration for debt instruments under Article 340(3) CRR

Unrated short term claim/exposure

As per CRR Article 120(para 3, subpara c), it states: "If there is a short-term assessment and such an assessment determines a less favourable risk weight than the use of the general preferential treatment for short-term exposures, as specified in paragraph 2, then the general preferential treatment for short-term exposures shall not be used and all unrated short-term claims shall be assigned the same risk weight as that applied by the specific short-term assessment." Question: 1. Is the term claim and exposure used interchangeably and mean the same? 2. What is meant by unrated short term claim in this paragraph? If there is a general issuer rating available for the counterparty, but no issue specific rating for the exposure to the counterparty, will the exposures with residual maturity of less than 3 months be classed as Unrated and not eligible for preferential risk weight treatment as per CRR Article 120 (2)? 3. Also, for ex- if the bank has trading book exposure to this institution for exposure less than 3 months. But this institution has issued short term debt, but the bank has no exposure to it, in that case which rating will be used to risk weight the exposure in the trading book. Will it be the issuer rating or short term debt rating the institution has issued which the bank has no exposure?

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

Definition of 'explicit guarantee arrangements' for the purpose of classification of non-commercial undertakings as public sector entities

What conditions should be met by a given agreement in order to qualify as an 'explicit guarantee arrangement'? Shall the ‘explicit guarantee arrangements’ for the purpose of definition of public sector entities also be ‘guarantees’ eligible as unfunded credit protection or not? How much should the guarantee cover?

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

Maximum amount of the collateral or guarantee that can be considered in F 13.01 and F 18.00

Could you please more precisely clarify what should be used for “Maximum amount of the collateral or guarantee that can be considered”? Primarily use Market value of collateral as it is prescribed in ESRB Recommendation? or Each Institute can have individual approach, where Internal collateral value (Market value of the assets reduced by a certain percentage => the “haircut”) also can be primarily used?

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

Exposures for trades at QCCPs (excluding initial margin and default fund contributions)

Under CRR Article 306/307 only default fund contributions are seperately calculated as an exposure to a CCP. Initial margin would be recognised within the standard exposure calculation per Article 306(3) as such it is unclear how to populate rows 0020 and 0080 seperately particularly as c0010/r0010 is greyed out and therefore no overall accurate exposure value is populatable. The format of the template seems more aligned to the calculation of EAD by the CCP itself for the purposes of calculating KCCP under Article 50b of Regulation 648/2012. This is particularly the case given the expectations set by validation rule v09847_m. Could you please clarify the correct reporting of these rows? Is it correct for example to report the value of initial margin (post any volatility adjustment and alpha) in row 0080/column 0010 and then just subtract the equivalent amount from the overall exposure to the CCP to report the remaining value in row 0020 such that the sum of the two will equal the total EAD to the CCP and maintain consistency with RWA for c0020? Alternatively should the template be resturctured to show only EAD and DFC rows and populate the full EAD as calculated under the CRR including initial margin in row 0020?

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

Definition of financial institution and mixed activity insurance holding company

Can a mixed-activity insurance holding company (MAIHC) that has at least one subsidiary credit institution pursuant to Article 4(1)(1) CRR qualify as a financial institution pursuant to Article 4(1)(26) CRR?

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

Specification and operationalisation of the phrase "at all times"

How is the wording in Article 92 (1) CRR to be understood with regard to compliance with own funds requirements “at all times” in terms of verifiability?

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

Validation rules of templates F 24.01 and F 24.02 specifically EGDQ_0665, EGDG_0666, XBRL v8035_m and XBRL v8052_m. These validations impose that the closing figures of the prior financial year end should tally with the opening figures of the current reporting quarter without allowing for reclassifications or changes of the counterparties’ reporting criteria segregated in F 24.01 and F 24.02, namely collateral type, and SME criteria.

For accounts which do not have a change in non-performing status, how are changes in collateral and/or SME status of the counterparty are to be reported in F 24.01 and F 24.02, since validation rules of templates F 24.01 and F 24.02, specifically EGDQ_0665, EGDG_0666, XBRL v8035_m and XBRL v8052_m, cannot all be complied with simultaneously when such changes occur after the previous financial year end?

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

Template C 08.01 – Validation rule v10667_m - {C 08.01.a, r0070, c0250} * sum({C 08.02, c0110, (rNNN)}) = sum({C 08.02, c0250, (rNNN)} * {C 08.02, c0110, (rNNN)})

Range of applicability of validation rule v10667_m in force starting from June 2023 with DPM 3.2.

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

Modelling the risk of migration from NMDs to term deposits in the context of the constant balance sheet assumption in the NII SOT.

Is it modelling the risk of migration from NMDs to term deposits consistent with the constant balance sheet assumption in the NII SOT?

Legal act: Directive 2013/36/EU (CRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2022/14 - Guidelines on interest rate risk arising from non-trading book activities

Reporting of liquid assets associated with the issuance of covered bonds

Should the liquid assets, up to net outflows, held as part of the liquidity buffer in the cover portfolio associated with the issuance of covered bonds, be reported as unencumbered?

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

C34.02 - reporting of VM, RC and PFE when EAD is capped for margined business under SA-CCR

Under SA-CCR, when EAD for margined business is being capped at EAD value as if unmargined business (as per CRR Article 274 (3)), should all the atributes of the netting set change in reporting as if it were unmargined business? Namely: - columns 0060 or 0070 should report no value as VM or report the VM posted/received in the margin agreement (in line with ITS)? - column 0100 should report the RC calculated as if unmargined (as per CRR Article 275 (1) formulae) or report the RC calculated based on the status of margined business (as per CRR Article 275 (2)? ; same for column 0110 for PFE - netting set should flow in row 0140, unmargined business, or in 0130, margined business (as it is contractually established)?

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

Reporting Requirements per type of institution

Are small and non-complex/other institutions required to use the simplified set of templates, or can they use the Large format if they already have to produce it, for example, for their holding/parent company?

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

Organisation and governance

Legal and policy framework

Careers

Supervisory convergence

Direct supervision and oversight

Information for consumers

Ad hoc activities

Risk analysis

Reporting frameworks

Data

Publications

Media centre