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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.

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List of Q&A's

NACE sector K- 'Financial and insurance activities' in F 06.01

Can EBA confirm that Holding companies, as defined in ESA 2010, are out of scope of template F06.01? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7245
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 13/01/2025

Geographical breakdown C 15 - inconsistency in parameter CEG

We would like to open a discussion regarding parameter CEG (geographical breakdown, "Country where the exposure is generated") used in corep_of report and the inconsistency of data entry for this parameter in template C 15 and templates C 9.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2024_7113
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 09/01/2025

Reporting of deferred tax assets on the C33.00 - Exposures to General governments template

CRR article 48 (4) requires deferred tax assets that are dependent on future profitability and arise from temporary differences (DTAs) that are not deducted from capital to be risk weighted at 250%. EBA Q&A 2013_390 clarifies that ‘net deferred tax assets which depend on future profitability and arise from temporary differences (DTAs) and which are risk weighted with 250% according to Article 48 (4) of Regulation (EU) No. 575/2013 (CRR) are assigned to the exposure class of the obligor’. ANNEX II – Reporting on Own Funds and Own Funds Requirements states that exposures risk weighted in accordance with Title II of Part Three CRR (Credit risk framework) should be included on the C33.00 - Exposures to General governments template (C33). However, DTAs are risk weighted under the ‘Own Funds and Eligible Liabilities’ section. In cases where DTAs are exposures to governments, should these be included on the C33.00 - Exposures to General governments template (C33) in column 290 and 300?

  • 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_7117
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 09/01/2025

Equity instrument subject to impairment in F20.04

The instructions for reporting the column "of which: financial assets subject to impairment [...]" regarding equity instruments (see F20.04 r0040 c0012) currently leave room for interpretation about the specific definition of "subject to impairment" to be applied. In particular, we would kindly ask the EBA to clarify whether a) the respective positions should be deactivated (i.e., greyed out) because of non-applicabilityb) there is a different expectation regarding equity instruments that has not been written in the Annex yet (in particular, equity instruments are subject to the IAS 36 impairment test).

  • 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_7258
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 09/01/2025

Reporting of ESCROW accounts (or other captive accounts) in template F08.01

In which row shall be reported Escrow accounts (or other captive deposits) from non financial companies in template F 08.01 ‘Breakdown of financial liabilities by product and by counterparty sector’?  Either as being ‘Current accounts/overnights deposits’ row 0270 or as ‘Deposits redeemable at notice’ row 0290 or as ‘Deposits with agreed maturity’ row 0280?  

  • 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_7262
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 09/01/2025

Definition of residential/commercial immovable property in FINREP reporting under CRR3

What should be considered as ‘residential / commercial immovable property for financial reporting purposes (FINREP)? Do the definitions change under CRR3?

  • 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_7270
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 09/01/2025

Calculation of the GAR and BTAR flow versus the previous disclosure period

For Small and Non Complex Institution and other institution, should the GAR and BTAR flow be calculated on a semi-annual or an annual basis?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7126
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 07/01/2025

Definition of weighted average maturity (WAM) and weighted average yield (WAY)

Can you please confirm that the WAM is based on the residual time to maturity according to the contractual conditions? Furthermore which notional amount shall be used for averaging: the notional amount at reporting date or future notional amount including any amortization payment? If we base the calculation of the  WAM on the residual maturity, wouldn’t we – for consistency reason also the yield to maturity to be reported under WAY?

  • 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
  • ID: 2024_7094
  • Topic: Supervisory reporting - IRRBB
  • Date of submission:
  • Published as Rejected Q&A: 12/12/2024

RSF from contributions to CCP default fund in C80.00

Should the "Unfunded default funds contributions to CCP" reported in rows 0100 and 0200 of C34.10 be reported in C 80.00 row 0960_"1.8 RSF from contributions to CCP default fund"?

  • 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_7081
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 12/12/2024

EBA Application of validation rules v10665_m

In EBA Quality Assesement 2023 Q4_data_package1-2,  we receive a warning for the validation rule v10665_m The TABLE_BASED_FORMULA is express as   {C 08.01.a, r0070, c0230} * (sum({C 08.02, c0110, (rNNN)}) - sum({C 08.02, c0140, (rNNN)})) = sum({C 08.02, c0230, (rNNN)}) * ({C 08.02, c0110, (rNNN)} - {C 08.02, c0140, (rNNN)})) But the formula used for the control (FORMULA_DPS) is the one below d81537 * (sum(d81290) - sum(d80911)) = sum(d81536) * (d81290 - d80911) It result in a incorrect calculation for the right side of the formula

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7051
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 12/12/2024

Disclosure of cash collateral received on derivative transactions in C40 template

Whether the cash collateral received in an account with other institutions should be excluded from disclosure in C40, {0210;0020} 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/11 - Guidelines on disclosure requirements under Part Eight of CRR
  • ID: 2024_7032
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as Rejected Q&A: 28/11/2024

Aggregated method for duration of derivatives

Could the EBA please clarify the expected method to aggregate and report the Duration value (column 0020) in template J 02.00 for derivatives?

  • 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_7238
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 28/11/2024

Reporting Requirements on exposures subject to behavioural modelling

What is expected to be reported on the template J08.00b in terms of the perimeter of exposures included in the reporting of relevant parameters? Only those exposures actually subject to behavioural modelling by the institution (thus excluding exposures exposed to Prepayment, NMD behavioural modelling and Early Redemption Risks but non modelled by the institution) or all the exposures exposed to such risks, including those on which models are not applied?

  • 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_7239
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 28/11/2024

Should repricing coupons be included in J06 sheets?

Should repricing coupons be included in J06 sheets in IRRBB reporting? EBA’s validation formula says that repricing coupons should not be included (validation rules v22320_m and v_22321_m). Otherwise the regulation (Final Draft RTS on Standardised Methodologies on IRRBB, Article 1, “’Notional repricing cash flow’ means: (c) Any interest payment on a part of the principal that has not yet been repaid or repriced) says that repricing coupons should be included. And if those repricing coupons are included (as the regulation says) it will cause validation rules v22320_m and v22321_m to be active because repricing notionals are always greater than the notional only.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7244
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 28/11/2024

FINREP Templates F25 and F13

It has come to our attention that Form F25.01.a contains data elements that overlap with Form F13.3.1. For instance, F25.01.a Row 0120 Column 0030 shares data with F13.3.1a Row 0020 Column 0010. From a business perspective, this inclusion appears incongruous, and we would appreciate an explanation of the rationale behind this decision. Could you please provide the logic and reasoning for including this shared data element between Form F25 and Form F13?

  • 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_7240
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 28/11/2024

Own funds requirement for asset-referenced token issuers

Are issuers of asset-referenced tokens, who are exempt from authorization requirement pursuant to Article 16(2) of MiCAR, subject to the own funds requirement pursuant to Article 35(1) of MiCAR?

  • Legal act: Regulation (EU) No 2023/1114 (MiCAR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7210
  • Topic: Own Funds (MiCAR)
  • Date of submission:
  • Published as Rejected Q&A: 21/11/2024

Consistency of treatment between the technical guarantees that are subject to the Pillar 2 requirement (Supervisory Expectation of the ECB) and the technical guarantees that are subject to the Pillar 1 requirement (Regulation EU 2019/630).

Should the exemption of technical guarantees from the backstop calculation subject to the Pillar 2 requirement) be extended to the technical guarantees subject to the Pillar 1 requirement?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7221
  • Topic: Supervisory review and evaluation (SREP) and Pillar 2
  • Date of submission:
  • Published as Rejected Q&A: 20/11/2024

Collateral Valuation

My question is in respect to the need for independence of valuers. Should a Bank' procedure allow customers to propose valuers subject to acceptance of the Bank and fulfilment of the independence criteria mentioned in the guidelines, would the Bank be considered as fulfilling the need for independence of valuer?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2020/06 - Guidelines on loan origination and monitoring
  • ID: 2024_7057
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 20/11/2024

Scope for dependent financial intermediaries

The dependent financial intermediaries (agents), who acting on behalf of credit institutions, are covered by the DORA Regulation?

  • Legal act: Regulation (EU) No 2022/2554 (DORA)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7142
  • Topic: Other DORA topics
  • Date of submission:
  • Published as Rejected Q&A: 15/11/2024

Powers of MiCAR authority to obtain the information needed to assess recovery and redemption plans and possible mechanism for exchange of information with the prudential authority

In cases where the MiCAR authority differs from the prudential authority under CRD, respectively the competent authority for recovery plans under BRRD, does the Regulation ensure that the MiCAR authority is provided with the powers to gather from the supervised entities (in the course of the ongoing supervision) all information that is necessary in order to duly assess the recovery and redemption plans of banks and investment firms? If there is a risk of insufficiency of information at the disposal of the MiCAR authority, what will be the mechanisms ensuring proper access of information by the MiCAR authority to the information available within the prudential authority on the financial indicators and other key metrics for the purposes of assessment of the recovery and redemption plans, as well as whether Member States are expected to implement special measures to ensure the protection of sensitive information? How the flow of information towards the CRD competent authority from the MICAR supervisors should be assured in order for CRD authority to be able to perform on their tasks? 

  • Legal act: Regulation (EU) No 2023/1114 (MiCAR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7067
  • Topic: Recovery plans (MiCAR)
  • Date of submission:
  • Published as Rejected Q&A: 15/11/2024