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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

“part of a group”

Does “part of the group” in the meaning of Art. 12 (2) IFR also include investment firms established in a third country?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7542
  • Topic: Capital requirements
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

Wording error in IFR/IFD regarding the method for calculating capital requirements for counterparty default risk (K-TCD)

Why is collateral posted to the counterparty ignored in the Exposure Value (EV) calculation for a cleared derivatives portfolio under a margin agreement with a negative Mark-to-Market?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7560
  • Topic: K-factor requirements
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

Calculation of dividend component at individual accounts of the institution

In the context of CRR article 314(2), should the dividend component (DC) at individual level include the dividends received from wholly owned subsidiaries?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7574
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

Obligations in Equity exposures of Article 133 (1) (c) (i) CRR

Does the term “obligation” in Article 133 (1) (c) (i) CRR refer to the principal amount, or does it also refer to the interest payment solely? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7631
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

Application of obligations relating to the default to ancillary services companies (such as operation leasing entities)

Is it necessary to apply in operating leasing entities the obligations of monitoring and controlling risks relating to the new definition of default (forbearance, early warning, etc.)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7515
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

Clarification on the relationship between Margin of Conservatism (MoC) and rating/calibration philosophy (PIT vs TTC) under EBA Guidelines on PD and LGD estimation (EBA/GL/2017/16)

According to the EBA Guidelines on PD and LGD estimation (EBA/GL/2017/16), the Margin of Conservatism (MoC) aims to address uncertainty arising from data and methodological deficiencies, changes in underwriting standards or risk appetite, and general estimation error. The Guidelines describe the three MoC categories (A, B, C) and the principles for quantification, but they do not explicitly refer to any link between MoC and the chosen rating philosophy (Point-in-Time vs Through-the-Cycle) or calibration philosophy. Could you please clarify whether the regulator expects the MoC concept to be aligned with the institution’s PIT/TTC philosophy, or whether MoC is entirely independent of the rating/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: 2025_7634
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

EBA publication of loss rates for Swiss residential and commercial property under CRR Articles 125 and 126.

Will the EBA publish loss rate data for Swiss residential and commercial property markets to enable institutions to apply preferential risk weights under Articles 125 and 126 CRR? If yes, what is the expected timeline?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7635
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

Calculation of the Exposure-to-Value (ETV) ratio and risk weighting when dealing with complex collateral structures

Under Articles 124, 125, and 126 of Regulation (EU) No. 575/2013 (CRR) as amended, how should institutions calculate the Exposure-to-Value (ETV) ratio and apply risk weighting when dealing with complex collateral structures involving multiple liens, syndicated financing, and mixed property types? Specifically: 1.      Is the exposure value defined in Article 111 the correct basis for determining the portion of exposure exceeding the lien amount? 2.      Should the ETV ratio be calculated only up to the nominal amount of the lien, or on the full loan amount? 3.      When a loan is secured by multiple properties, should the ETV be calculated as a single ratio using the aggregate property value, or should separate ETVs be calculated per lien/property? 4.      How should the gross exposure be adjusted when multiple first-ranking liens exist, some held by the institution and others by third parties? 5.      In syndicated loans where liens are shared pari passu among institutions, how should the exposure be compared to the nominal amount of the lien for risk weighting under Article 124(1)? 6.      In cases where the lien sequence is broken (e.g., junior liens held by third parties), is it permissible to distribute the property value across liens to optimise ETV ratios? 7.      Can an institution apply both the loan-splitting and ETV approaches to different parts of a single loan secured by multiple properties with varying characteristics (e.g., residential vs commercial)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7422
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

Application of general requirements of Chapter 6 of the Regulation (EU) No 575/2013 regarding the definition of own funds

Does the definition of „own funds“ in Article 4(46) of PSD2 refer to the definition of „own funds“ as defined in point 118 of Article 4(1) of Regulation (EU) No 575/2013 only, or are Articles 26 - 88 of Regulation (EU) No 575/2013, in particular Articles 26 (3), 77 and 78 of Regulation (EU) No 575/2013, also refered to by Article 4(46) PSD2?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7396
  • Topic: Other topics
  • Date of submission:
  • Published as Rejected Q&A: 12/12/2025

Netting of foreign exchange derivatives (as per Annex (II, a-e) of Reg. No 575/2013) in Net Stable Funding Ratio (NSFR)

What criterion should be adopted for the treatment of a foreign-exchange derivative contract included in a netting set between what reported in Article 428d(4) and in Article 428d(2) of CRR2?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7625
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 11/12/2025

Loans for ADC (Loan for Acquisition, Development and Construction) with underlying exposure residential mortgage

Considering Basel IV (CRR3) was published after the latest NSFR template instructions. Our interpretation is that there are two possibilities: EBA keep the existing wording allowing only exposures secured by mortgages on residential property or EBA amends the wording for NSFR c80 row 0810 and allows any exposures secured by mortgages and loans on residential property.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7557
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 11/12/2025

C 66.01 Contractual Maturity Ladder: Eligibility of retained covered bonds issued and received by other members of the same group as counterbalancing capacity

Can a credit institution include in its initial stock of counterbalancing capacity in the C 66.01 contractual maturity ladder central bank-eligible covered bonds that constitute retained own issuances from another member of the same group?

  • 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
  • ID: 2025_7507
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 11/12/2025

Finrep Validation Rules v4975_m and v6058_m6

The validation rules v4975_m and v6058_m appear to systematically fail when institutions hold loans measured at fair value through other comprehensive income (FVOCI). These rules seem not to reflect that fair value remeasurement adjustments on FVOCI loans are recognised directly in the balance sheet through equity. Could the EBA confirm whether these validation rules should exclude FVOCI instruments from their scope, or whether they will be revised to properly reflect valuation adjustments recognised in the balance sheet under IFRS 9?

  • 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
  • ID: 2025_7611
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 11/12/2025

Umgang mit unwiderruflichen Zeichnungszusagen für Fondsanteile im Kreditrisiko Kurzbeschreibung: Zuordnung und Risikogewichtung von Zeichnungszusagen in den Phasen der Fondsauflegung

Im Rahmen der Abbildung unwiderruflicher Zeichnungszusagen für Fondsanteile in unserem Spezialfonds stellen sich uns folgende Fragen:1.    In welcher Forderungsklasse des Kreditrisikos nach 575/2013 der CRR (CIU gem. Art. 132 oder Unternehmen gem. Art. 122) sind unwiderrufliche Zeichnungszusagen während der Phase 3(Auflegung des Sondervermögens) sowie während der Phase 4 (nach Auflegung des Sondervermögens) zuzuordnen?2.    Mit welchem Risikogewicht sind diese Zusagen in den jeweiligen Phasen zu bewerten? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)
  • ID: 2025_7582
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 02/12/2025

Corporate exposures in C10.00 memorandum lines r0250 and r0260

In template C10.00, institutions that apply the IRB approach, shall break down IRB exposures by SA exposure class. This template includes the following 2 memorandum lines: r0250 Corporates - F-IRB  r0260 Corporates - A-IRB How should 'Corporates' be interpreted for these two memorandum lines? Does that relate to the volume reported on rows r0100 (Corporates - other) and r0120 (corporates - specialised lending) of template c10.00? The ITS does not clarify this. Therefore the question is whether the sum of rows r0250 and r0260 should reconcile with the sum of C10.00 rows r0100 and r0120? An alternative interpretation is that the SUM of rows r0250 and r0260 should reconcile with the sum of corporate exposures reported in the C08.01 IRB template. We feel that this alternative interpretation is not logical as it would repeat numbers already (separately) reported in C08.01 and separately identifiable, both whether it relates to 'corporates' and whether it relates to A-IRB and F-IRB is identifiable via the Z-axis. Therefore we feel that this interpretation will not add any added value. Could you please clarify to which 'Corporates' lines r0250 and r0260 refer?

  • 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
  • ID: 2025_7624
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 27/11/2025

v6332 - Negative FV changes os hedged intems (C 32.01)

In relation to Q&A 2022_6511 where a question was raised related to validation rule v6566_s. We believe validation rule v6332_m should be deactivated for row 120.

  • 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: 2025_7619
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/11/2025

Liability category of margins received

Could you please clarify if margins received, part of a repo or derivative netting agreement can always, regardless of whether the netting results in a net liability or asset position, be considered r0120 - Secured liabilities, or should be allocated to other liability categories as defined in Resolution Plans report Z02? 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on the provision of information for the purpose of resolution plans
  • ID: 2025_7615
  • Topic: Resolution plans
  • Date of submission:
  • Published as Rejected Q&A: 27/11/2025

Requirements of Z 11.00 for RLE that are not institutions

Article 3 - Group resolution reporting  We observed some differences, especially for the Z 11.00 template when comparing the 2 parts of the final draft below: the draft proposal to the commission (chapter 3 Draft Implementing Technical Standards, article 3) and the tab in accompanying documents (chapter 2 Background and rationale - 2.2.4 Overview of revised reporting obligations). It seems there is no article requiring specifically from RLEs that are institutions to report Z 11.00 template, although it is included in the tab "Overview of revised reporting obligations". The Z 11.00 template is mentioned in paragraph 7, which seems to either concern the resolution entity or the scope of the article seems to be (too) large (all entities?). Could you please confirm whether Z11.00 template is required for RLE that are not institutions? Other information: In order to compare with Z02.00 requirements, paragraph 3 (a) specifically required Z 02.00 for RLE that are institutions.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on the provision of information for the purpose of resolution plans
  • ID: 2025_7581
  • Topic: Resolution plans
  • Date of submission:
  • Published as Rejected Q&A: 27/11/2025

Calculation rule

Please precise calculation rules for : number of transactions on proprietary accounts (column 0100) number of transactions on clients accounts (column 0110) Cumulated notional amount  (column 0140)

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/1624 - ITS on the provision of information for resolution plans
  • ID: 2025_7572
  • Topic: Resolution plans
  • Date of submission:
  • Published as Rejected Q&A: 27/11/2025