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Accommodation and food service activities

Should accommodation and food service activities (NACE I) be considered an activity sector that significantly contributes to climante change?

Legal act: Regulation (EU) No 575/2013 (CRR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR

Exemption from deduction of Equity Holdings in an insurance company from CET1

Institution “A” currently applies the exemption provided under Article 471 CRR, whereby it does not deduct from its own funds a qualifying shareholding held in Insurance Undertaking “C” for an amount not exceeding the amount held in CET1 instruments issued by that Insurance Undertaking as of December 31, 2012 . Following the completion of a merger by absorption between Institution “A” and Institution “B” – as a result of which Institution “B”, as surviving entity, becomes the direct holder of the shareholding in Insurance Undertaking “C” by virtue of universal succession – is Institution “B” entitled to continue to apply the exemption under Article 471 CRR, as previously applied by Institution “A” in respect of such shareholding? Upon completion of the merger mentioned in question 1 above, would Institution “B” be entitled to apply the exemption under Article 471 CRR on a consolidated basis in case its direct shareholding in Insurance Undertaking “C” is transferred (as a result of a partial de-merger) to its wholly owned subsidiary Institution “D”, given that the shareholding in Insurance Undertaking “C” would in any event be held within the consolidation perimeter of Institution “B”? 

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

Definition of "main business" under CRR

How are banks to interpret the concept of "main business" in Article 411(1) of Regulation (EU) No 575/2013 (CRR), read in conjunction with Annex I of Directive 2013/36/EU and Article 3(9) of Commission Delegated Regulation (EU) 2015/61? In particular: can an entity be considered to perform Annex I CRD activities as its "main business" within the meaning of Article 411(1) CRR if: there is an absence of any third-party commercial activity i.e. entity does not offer financial services to any external party for commercial consideration nature of the entity’s operations is ancillary to the group and it exists solely as an instrument of the group's non-financial operations with no independent commercial purpose

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

Clarification of ETV calculation for mortgages securing more than one exposure

Article 124 paragraph 6 Regulation (EU) No 575/2013 (CRR) specifies the calculation of ETV for IPRE exposures. In order to calculate ETV, the gross value of an exposure should be divided by the value of property. Additionally, this article clarifies that: “For the purposes of the first subparagraph, point (a), where an institution has more than one exposure secured by the same immovable property and those exposures are secured by liens on that immovable property that are sequential in ranking order without any lien held by a third party ranking in-between, the exposures shall be treated as a single combined exposure and the gross exposure amounts for the individual exposures shall be summed up to calculate the gross exposure amount for the single combined exposure.” Our question refers to calculation ETV for joint mortgages – so the mortgage which secures more than one exposures and additionally these exposures may have other mortgages assigned. Based on the above, it’s clear that numerator should include the gross value of all exposures secured by this joint mortgage. Nevertheless, it’s unclear which value should be used in the denominator of ETV in the real life example described below.

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

Risk weights assignment to IPRE exposures secured by many properties

Articles 125 and 126 paragraph 2 Regulation (EU) No 575/2013 (CRR) specify the rules for risk weights assignment to IPRE exposures, respectively secured by residential and commercial properties. However, these regulations don’t clarify how risk weights should be assigned to IPRE exposure when it’s secured by both residential and commercial property – especially when one property is IPRE (income producing property) and the second one is non-IPRE (the residential property, let’s assume that this is the flat of a counterparty). 

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

Financial Conglomerates: Reporting of exposures by counterparty within the FC.06 template in light of the reference to “connected client groups” according to Article 4(1), point (39), of Regulation (EU) No 575/2013 and the response to Q&A “2025_7381"

We are seeking clarification about a possible mismatch between ITS and DPM 3.5 (ID v22748_u - T1 L 06.00, column c0020) as part of the compilation of the template FC.06 Template - “Risk Concentration - Exposure by counterparties" within the FiCoD supervisory reporting. In particular, Commission Implementing Regulation (EU) 2022/2454 of 14 December 2022 refers to Article 4(1), point (39), of Regulation (EU) No 575/2013 with reference to the concept of “group of connected clients” for the purposes of reporting in the FC.06 template Risk Concentration – Exposure by counterparties.  If applied the alternative approach, this could require representing on separate rows cases where the same external counterparty simultaneously belongs to a group of connected clients whose parent entity is the central government, as well as to another group of connected clients, resulting in the loss of the uniqueness criterion for records based on the current DPM and the responses provided by the EBA in Q&A ID_2025_7381. We therefore ask whether, for the purposes of reporting in the FC.06 template: the reference to Article 4(1), point (39), of Regulation (EU) No 575/2013 should be considered binding and, consequently, whether the FC0040 column “Name of the group (in case of group of counterparties)” should be regarded as a key value for the unique representation of exposures towards external counterparties in case of an affirmative answer, which would imply the repetition of the same exposures towards the same external counterparty across multiple rows of the FC.06 template, what the allocation criterion for the exposures across the rows should be. Additionally, in case of an affirmative answer for the purposes of reporting in the FC.06 template, we ask what the allocation criterion for the exposures for the purpose of reporting in FC.07 is, as the application of this regulatory reference would imply considering the same exposures to the same external counterparty multiple times.

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

Reporting of minority interest on the NSFR

In the Annex XIII of the applicable reporting framework, and regarding the COREP C 81.00, within the NSFR ITS decision tree, Question 2 refers to “Additional Tier 1 capital” (ID 2.1.2), while Question 11 refers to “Minority interests” (ID 2.9.3). Should qualifying minority interests that relate to Additional Tier 1 capital instruments be reported: under the “Additional Tier 1 capital” row (ID 2.1.2), or under the “Minority interests” row (ID 2.9.3)? 

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

Ban imposed by certain national authorities on the use of the term “neobank” for payment institution

Does the divergence of positions among national authorities regarding the freedom to use the term "neobank" for payment institutions not compromise the consistent application of EU law in the banking sector and the objective of convergence of supervisory practices, and does it not hinder competition and the development of cross-border activities? 

Legal act: Directive 2015/2366/EU (PSD2)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Requirement for a consolidated ICARA process under Directive (EU) 2019/2034

Does Directive (EU) 2019/2034 require investment firms that are subject to prudential consolidation under Article 7 IFR to prepare, maintain and document an ICARA process on a consolidated basis? In particular, does Article 25(4) IFD impose an obligation to perform the ICARA at consolidated level, or does it merely extend the application of Part Three without creating a standalone consolidated‑ICARA requirement?

Legal act: Directive (EU) 2019/2034 (IFD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Reporting of registered covered bonds issued by the reporting institution

Is the definition of covered bonds issued in the context of F 35.00 ("Covered bond issuance") also applicable for F32.04 ("Sources of encumbrance");  i.e. should registered covered bonds issued by the reporting institution in compliance with 2009/65/EG; article 52; paragraph 4 be reported in lines 90 ("Debt securities issued") and 100 ( "of which: covered bonds issued") of F32.04?

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)

Identical cell F_13.02.1 Collateral obtained during the period

Could you pls de-activate the 'identical cells' below in DPM 4.2.1? VariableVID = 5459395 ---> {F_13.02.1.a, r0020, c0010}=={F_13.02.1.c, r0080, c0040} ----> 120783==366904 VariableVID = 5460187 ---> {F_13.02.1.a, r0020, c0020}=={F_13.02.1.c, r0080, c0050} ----> 120791==366905    

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

Scope of the exemption under Article 7(7) with respect to Level 1 assets referred to in Article 10(1)(c)

Do the requirements laid down in Articles 7(5) and 7(6) of Delegated Regulation (EU) 2015/61 apply to assets referred to in Article 10(1)(c)?

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

When trying to submit reports to our portal Finanssivalvonta it gives us this error: An error occurred while converting CSV to XML. Error while reading CSV instance: error:unresolvableBaseMetadataFile ; : The resource "http://www.eba.europa.eu/eu/fr/xbrl/crr/fws/corep/4.2/mod/corep_of.json" is missing

When trying to submit reports to our portal Finanssivalvonta it gives us this error:     An error occurred while converting CSV to XML. Error while reading CSV instance: error:unresolvableBaseMetadataFile ; : The resource "http://www.eba.europa.eu/eu/fr/xbrl/crr/fws/corep/4.2/mod/corep_of.json" is missing. What does this mean? we cant seem to figure that out

Legal act: Other
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Own funds requirement for entities authorized as Crypto Asset Service Provider (CASP), Electronic Money Institution (EMI) and Investment Firm (IF)

How should own funds requirements be determined for a legal entity authorised as a crypto-asset service provider (CASP) under Regulation (EU) 2023/1114 (MiCAR), as an electronic money institution (EMI) under Directive 2009/110/EC, and as an investment firm under Regulation (EU) 2019/2033 (IFR) and Directive (EU) 2019/2034 (IFD), in particular where certain crypto asset services – such as the transfer of crypto assets on behalf of clients – require a specific CASP authorization rather than a notification regime, and given the absence of explicit provisions governing the interaction between the two prudential frameworks?

Legal act: Regulation (EU) No 2023/1114 (MiCAR)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Shadow Banking Definition - Alternative Investment Funds

Where an entity qualifies as an alternative investment fund (“AIF”) for the purposes of Directive 2011/61/EU, but its constitutive documents do not explicitly prohibit loan origination or the purchase of third‑party lending exposures, should that entity be regarded as meeting the criterion in Article 1(c)(iii) of the relevant Delegated Regulation 2023/2779 (Identification of Shadow Banking) solely on the basis of what it is permitted to do, notwithstanding that it does not in practice carry out banking activities, as referred to in Article 394(2) CRR? In particular, should the assessment of whether an AIF falls within the definition of a shadow banking entity be determined by: the theoretical scope of permitted activities under its rules or instruments of incorporation, or the actual activities carried out by the AIF in the ordinary course of its business?

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

Z03.01 - Own funds requirements on individual level: r0300 / r0500 if a waiver exists

According to EBA validation rule v6433_m a minimum Total SREP Capital Requirement (TSCR) ratio (r0300) of 0.08 should be reported. However, the reporting subject has been granted a waiver from the minimum capital requirements under Article 92 CRR and is not required to comply with the 8% Total Capital ratios on a standalone basis, as these requirements are fulfilled and monitored at the consolidated group level. This also affects the "Overall capital requirement (OCR) ratio" (r0500) due to validation rule v6436_m. If the validation rule v6433_m will not be deactivated, which value needs to be reported in such cases?

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Z09.02 Requirement to Report CEF and Its Country When an FMI Only Supports a CBL

According to the EBA instructions, columns c0020, c0030, and c0040 are exclusively intended for essential FMIs (CEFs). However, in the template taxonomy, even when selecting “No” in column c0020 to indicate that the FMI is not a CEF, the system still requires completion of columns c0030 and c0040. We do not fully understand this requirement: if we have indicated that the FMI is not a CEF, we should not be expected to provide any CEF in column c0040, nor the CEF country in column c0030. Could you please advise on how we should proceed? As it stands, we would either need to enter an arbitrary CEF for FMIs that support a CBL but not a CEF, or the system should allow leaving columns c0030 and c0040 blank when c0020 = “No”.

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Inability to Assign More than One CEF or CBL to an FMI

It is currently not possible to report more than one CBL (c0050–c0060) per FMI (Z09.02).Historically, several FMIs have been reported as contributing to two Core Business Lines; however, upon uploading the data now, the system only accepts one CBL per FMI. Could you please confirm whether this is the expected treatment? If so, which CBL should be selected when both are equally relevant and one must be discarded in order to complete the submission?

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Z 03.01 - Validation rule V7511_m_0

We encounter an error on template Z 03.01 due to validation rule v7511_m_0. For the total amount c0010 in row r0400 the validation rules checks if the sum of r0410 + r0420 + r0430 + (max r0440; r0450) = r0400. Should the validation rule not also take into account the row r0460? 

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting

Instructions to follow regarding new EBA Resolution Reporting - Template Z 08.04

According to ITS, the c0040 "ID" column should be key, but in reality it is not. This does not allow for the representation of the connections between Critical Services (combination of c0005, c0010, and c0020) and multiple Critical Functions (c0040).

Legal act: Directive 2014/59/EU (BRRD)
COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

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