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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

Contradiction between the Validation Rule EGDQ_0766a and Methodology

We kindly ask for a clarification in regard to Template C34.03: EBA Validation rule EGDQ_0766a requires that the Total number of transactions in template C34.02 must be higher or equal the Total number of transactions in Template C34.03. In Template C34.03 the total is calculated by the Software (Abacus) based on the Number of deals in separate Risk categories: "Interest Rate Risk", "Foreign Exchange Risk", "Credit Risk",   "Equity Risk"  and "Commodities". 

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2024_7266
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2025

C34.10, reporting of rows related to margin information

What is meant to be reported on rows 0070, 0080, 0170 & 0180 of C 34.10: the exposure values of derivatives or the margin information of 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)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_7208
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2025

Signage of Model Risk Fair Value Adjustments reported in C32.02 (v6575_s)

Model Risk FVAs taken due to market or product factors not captured by a valuation model can be either positive (resulting in a P&L loss) or negative (resulting in a P&L gain). Where the adjustment would result in a P&L gain, it should logically be populated with a negative value. However, validation rule v6575_s states that FVAs reported must be greater than or equal to zero. Please confirm if Model Risk FVAs resulting in a P&L gain should be reported with negative signage in column 0190 of the COREP C32.02 template.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/101 - RTS for prudent valuation under Article 105(14) CRR
  • ID: 2024_7206
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2025

C 07 - Clarification on reporting the effect of the FX Mismatch

We seek clarification on some topics in regard to the newly introduced reporting requirements of the FX Mismatch (Art. 123a CRR III) in C07.The changes have been introduced with the final draft of the ITS templates for columns 0215 and 0220 to exclude/include the fx mismatch effect. 1. Our assumption is that the validation rules asking for consistency between column 0200, 0215 and the riskweight of the row in which the exposure is reported will still exist in the future. (e.g. v0324_m etc)Can you therefore confirm that the expectation for exposures affected by the fx mismatch is that they are to be reported in the row for the "unadjusted" riskweight instead of the riskweight including the effect of the fx mismatch? 2. as no specific column for the effect of the mismatch was introduced, can you confirm that validation rule v0329_m will become obsolete?

  • 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_7182
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2025

Template C 34.06 column 0040 & C 34.06 EBA_v10236_a

Shall counterparties having 'Households' counterparty sector be reported in C 34.06 template?

  • 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_7138
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2025

Remittance date for quarterly iMREL/iTLAC Q1 2025

Will the remittance date for Q1 2025 iMREL/iTLAC reporting be aligned to the due date for COREP reporting for which the submission date is postponed to June 2025?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/763 – ITS with regard to the supervisory reporting and public disclosure of MREL
  • ID: 2025_7298
  • Topic: MREL
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2025

Supervisory Factor for Credit Derivatives with underlying securitization for SA-CCR

The supervisory factor for the credit risk category add-on is to be assigned based on the rating assigned to the issuer of the underlying credit derivative.For securitisations, should the rating of the SPV issuing the various tranches be used or can the rating of the tranche be used? If the SPV is not rated but the tranches are, should the exposure be considered unrated?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7216
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 20/01/2025

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