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.

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

List of Q&A's

Annex XI - Leverage (template C43)

It is not clear from the instructions what exposure amount is expected to be reported for items deducted from capital in the columns dedicated to RWEAs in C43.

  • 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
  • ID: 2022_6650
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as Rejected Q&A: 22/03/2023

Clarification on reporting of “Total Assets” within C40.00 {0410;0010}, as defined in Annex XI.

Annex XI defines {C40.00, r0410, c0010} as “the total assets following the scope used in the published financial statements.” Having regard to the meaning of the word “published” used within this context, please confirm whether the total assets to be reported in C 40.oo must necessarily be equivalent to the total assets disclosed in the latest interim or year-end published financial statements. If in the affirmative, this would imply that, for institutions with only semi-annual and year-end publication dates (as opposed to quarterly publications), {C 40.00, r0410, c0010} shall not be updated within two quarters during a calendar year, given that such figure would be held constant as per latest publication. If this treatment is confirmed, our question further extends to the intended reporting of constituent rows, such as C 40.00 r0010, c0010} and {C 40.00, r0090, c0010}. We understand that the scope of reporting shall be consistent across the entire template, therefore for such rows, we would like to confirm whether they shall also be kept constant as per latest published financial statements, given the lack of instruction to these specific rows.

  • 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
  • ID: 2022_6641
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as Rejected Q&A: 22/03/2023

Withdrawable Central Bank Reserves in ALMM C 66.01 when considered Liquid Assets

Where should withdrawable Central Bank Reserves that are considered Liquid Assets according to Regulation (EU) 2015/61 be allocated in ALMM C 66.01 Maturity Ladder?

  • 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
  • ID: 2022_6619
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 22/03/2023

Treatment of amortization and interest flows - received within 30 days - from securities

ANNEX XXV REPORTING ON LIQUIDITY (PART 3: INFLOWS) clarifies the treatment of inflows from securities maturing within 30 days Row 190, ID 1.1.5. What is the correct treatment of amortizable securities for which capital repayments occur within 30 calendar days ? What is the LCR treatment of interest inflows from securities that occur within LCR horizon ? 

  • 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
  • ID: 2022_6381
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 22/03/2023

Interpretation of the appropriate estimator for Credit Conversion Factors (CCF)

Is it possible to interpret the concept of “default weighted average from all observed defaults” as described for realised CCFs in article 182 of Regulation (EU) No 575/2013 as amended by Regulation (EU) 2019/876 as “the arithmetic average of the yearly averages”?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6684
  • Topic: Model validation
  • Date of submission:
  • Published as Rejected Q&A: 21/03/2023

Model implementation timeline given the received permission in relation to a material change

In accordance with Article 3(5) of Delegated Regulation 529/2014, “Where competent authorities have provided their permission in relation to a material extension or change, institutions shall calculate the own funds requirements based on the approved extension or change from the date specified in the new permission which shall replace the prior one. The non-implementation on the date specified in the new permission of an extension or change for which permission from competent authorities has been given, shall require a new permission from competent authorities which shall be applied for without undue delay”. It is not clear what does “the date specified in the new permission” refer to.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 529/2014 - RTS on materiality of extensions and changes in the advanced approaches (IRB and AMA)
  • ID: 2023_6688
  • Topic: Model validation
  • Date of submission:
  • Published as Rejected Q&A: 21/03/2023

Financial Guarantees in templates Z 05.02 / T 12.00

Annex II states that "Major off-balance sheet counterparties shall be identified by summing up the total nominal amount of commitments and financial guarantees received (as defined for the purposes of FINREP, template F 09) by the entity or group entities for which the template is reported from counterparties or group of connected clients".  With regard to financial guarantees received, do all the financial guarantees received where the Institution is the beneficiary of the guarantee (thus including the guarantees that cover bank's assets and not liabilities) have to be reported in template F 09.02? Or should for templates Z 05.02 / T 12.00, only the financial guarantees where the reporting Credit Institution is the counterparty guaranteed (thus covering its liabilities) be considered or, as for F 09.02, also the financial guarantees received where the reporting Credit Institution is the beneficiary (thus covering its assets)?

  • 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: 2021_6109
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 21/03/2023

Assets encumbered for a residual maturity of one year or more in a cover pool funded by Covered bonds for NSFR purposes

Does the 85 % required stable funding factor apply to assets encumbered for a residual maturity of one year or more in a cover pool funded by Covered bonds issued directly in the market, as well as to the assets underlying self-issued Covered bonds used as collateral for long term ECB funding or SFT with the market?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6096
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 21/03/2023

Credit risk framework applicable to investments in repack Notes issued by SPEs

What is the applicable credit risk framework in the non-trading book applicable to investments in repack Notes issued by Special Purpose Entities (SPEs)? How should an institution calculate the risk weight of an investment in a Repack Note if it does not consolidate the SPE but is able to look through to the underlying assets at all times?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5400
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 21/03/2023

MREL/TLAC EBA template – split of liabilities by creditor hierarchy

Does the maturity split of own funds and potentially eligible liabilities for MREL in template M 06.00 of the ITS on disclosure and reporting on MREL and TLAC include prudential filters or not?

  • 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: 2021_6309
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 17/03/2023

v10811_m, grandfathered T2 instruments in M 06.00

How shall grandfathered T2 instruments with a residual maturity of less than 1 year be reported in M 06.00 - Creditor ranking (resolution entities) (TLAC3)?

  • 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: 2021_6223
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/03/2023

Is it correct that, in sheet Z 10.02, the Critical Function ID is not considered as a Key Value?

If the Critical Function ID is not considered as a Key Value, how can we represent the case in which we have a single critical service ID (and a single System identification code) on which there are multiple critical functions impacted?

  • 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: 2020_5529
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 15/03/2023

Credit card debt as Credit for Consumption

In order to clarify the answer given to Q&A 5167, should credit card debt be included as Credit for consumption when it comes to FINREP templates?

  • 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
  • ID: 2021_6219
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 14/03/2023

Reporting of Counterbalancing capacity (C66.01 of ALMM reporting)

After reporting template C66.01 we received an error related to validation rule: eba_v10660_m. We asume that the validation rule is inconsistent and want to explain. As a result of reporting C66.01b “Withdrawable central bank reserves” (r0740, c0010) you have to report this as a part of “Cummulated Counterbalancing Capacity”(r1080, c0010). You also have to fill C66.01a “Withdrawable central bank reserves” (r0740, c0020) with a negative indicator, but also at “Net change of Counterbalancing Capacity”(r1070, c0020) and  “Cumulated Counterbalancing Capacity” (r1080, c0020). When you report this as mentioned {C 66.01.a, r1080, c0020} is not equal to {C 66.01.b, r1080, c0010} + {C 66.01.a, r1070, c0020} as expected by validation rule v10660. Please can you explain how we have to solve this issue?

  • 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
  • ID: 2023_6719
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 06/03/2023

COREP v.3.2, C 08.01

Columns 150- 210 :CREDIT RISK MITIGATION TECHNIQUES TAKEN INTO ACCOUNT IN LGD ESTIMATES EXCLUDING DOUBLE DEFAULT TREATMENT The addition of the following additional instructions “The reported collateral values shall be capped at the exposures value.”is not consistent with answer of FAQ 2017_3349 which specifies “The amount of collateral taken into account for a specific exposure does not have to be capped at the exposure value of the exposure in question.” Should the amounts of collateral declared be capped at the value of the exposure?

  • 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
  • ID: 2023_6707
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 03/03/2023

DPM 3.2 validation rule v11366_m for C84

This validation rule checks the following formula:   {C 84.00.z, r0120, c0030} = {C 84.00.x, r0010, c0020} * {C 84.00.w, r0220, c0040}   Our institution reports available funding for USD in datapoint in C 84.00.z, r0120, c0030}.   However our institution does not have any required stable funding for USD to be reported in datapoint {C 84.00.x, r0010, c0020}.  Therefore no USD NSFR ratio can be reported in datapoint {C 84.00.w, r0220, c0040}. Question is how to report these figures to comply to this validation rule in case no required funding and NSFR ratio for USD can be reported?

  • 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
  • ID: 2023_6690
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 03/03/2023

How to fill in row 0150 on "Equity" in C 08.07

In the C08.07 report, column 0010 'TOTAL EXPOSURE VALUE AS DEFINED IN ART 166 CRR' refers to Article 166 which applies to exposures to companies, institutions, central governments and central banks and retail customers. If this column concerns the elements mentioned in Article 166, row 0150 “EQUITY” should not be filled in column 0010. Can you tell us if row 0150 “EQUITY” in column 0010 “TOTAL EXPOSURE VALUE AS DEFINED IN ART 166 CRR” must be completed?

  • 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
  • ID: 2022_6657
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 03/03/2023

Reporting of Negative Fair Value Hedge Adjustments as exposures

How should the fair value hedge adjustment amounts be reported in template C 08.01 in Annex I of Regulation (EU) 2021/451? Is it acceptable to report the exposures on row 0170 ‘Exposures from free deliveries applying risk weights under the alternative treatment or 100% and other exposures subject to risk weights’? Consistently, should EBA validation rules v0330_m, v0333_m, v0334_m, v10312_s and v10485_s be amended in a way not to trigger validation errors in cases where the fair value hedge adjustment amounts get negative values?

  • 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
  • ID: 2022_6575
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 03/03/2023

Deactivating Validationrule v10549_h

The validation rule v10549_h should be deactivated?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6313
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 03/03/2023

Reporting of IRB exposures in the form of units or shares in Collective Investment Undertakings (CIUs) treated under the Fall-Back Approach (FBA)

When applying the credit risk IRB approach, in which template and field shall institutions report exposures in the form of units or shares in CIUs treated under the new FBA (pursuant to Article 152(6) CRR)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2021_6040
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 03/03/2023