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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

Template 2: location of the collateral

Is it intentional to show the location of counterparty rather than the physical location of the property in question for Template 2 ?

  • 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: 2025_7461
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 11/07/2025

List of IEA Sectors in Column a vs List of IEA Sectors in the EBA3.3 Annotated Table Layout for ESG

The sector named "Chemicals" is listed in the Template 3: Banking book - Climate change transition risk: Alignment metrics, but is missing from the List of NACE sectors to be considered. There is therefore no indication of the NACE codes to consider for Chemicals. The answer to question 2024_7085 confirms that institutions shall also present IEA sector Chemicals as one of the rows for Template 3, but doesn´t tell which NACE sectors are to be used. Which NACE codes should be considered for the sector of Chemicals?

  • 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: 2025_7451
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 11/07/2025

BTAR voluntary disclose and DPM templates

Regarding the generation of DPM templates containing ESG pillar 3 disclosure, included in reporting framework 3.3 for the ad-hoc collection, according to Commission Implementing Regulation (EU) 2022/2453, template 9 – Mitigating actions: BTAR- was required for December 24 submission only on a voluntary basis.  In case a bank has decided not to publish BTAR template in the Pillar 3 disclosure for December 2024, our understanding is that there is no obligation to deliver, for December 2024, these templates (D 09.01, D 09.02.a, D 09.02.b, D 09.02.c, D 09.02.d, D 09.03.a, D 09.03.b) included in reporting framework 3.3 to keep both reports aligned (Pillar 3 disclosure, made public in February 2025, and the reporting framework 3.3 templates). Please confirm that our view on this subject is correct.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2025_7424
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 11/07/2025

Definition of ICT service

If a supplier must provide an ICT Service to fall under DORA, how should we determine what qualifies? Should we rely on the DORA regulation’s definition of an ICT Service, or should we use the Annex 3 list (S01-S19) from the ITS Register of Information?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information
  • ID: 2025_7415
  • Topic: ICT-related incidents (management / classification / reporting)
  • Date of submission:
  • Published as Rejected Q&A: 09/07/2025

Dora agreements - ICT service supports a CIF

When an ICT Service supports a Critical and Important Function (CIF) within a financial entity, providers must sign DORA agreements with their suppliers if the supplier: a)     Provides an ICT Service (as per the DORA definition). b)     Critically underpins the ICT Service, meaning its disruption could affect security or continuity (based on ITS on Register of Information, Article 3(2)(b)). Is this interpretation correct? Or must DORA agreements be signed with all critical suppliers, even those that do not provide ICT Services?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information
  • ID: 2025_7414
  • Topic: ICT-related incidents (management / classification / reporting)
  • Date of submission:
  • Published as Rejected Q&A: 09/07/2025

Register of ICT Services

Are these listed listed types of ICT-services (e.g., S07, S11, S12) covered under DORA’s definition of ICT Services? If not, can, e.g., facilities or infrastructure that do not include data or digital elements be excluded from this definition?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information
  • ID: 2025_7412
  • Topic: Register of information (DORA)
  • Date of submission:
  • Published as Rejected Q&A: 09/07/2025

Definition of landline services

What are landline services in this context? Could it include fiber optics (e.g., black fiber)?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7410
  • Topic: ICT-related incidents (management / classification / reporting)
  • Date of submission:
  • Published as Rejected Q&A: 09/07/2025

Discretionary pension benefits

According to Section 151 of the EBA Guidelines on sound remuneration policies under CRD (EBA/GL/2021/04) (“EBA Guidelines”), pension benefits that are not performance-based and are consistently granted to a category of staff as part of the company’s pension scheme should be regarded as routine employment packages. How should the concept of a “company’s pension scheme,” as referred to in Section 151 of the EBA Guidelines, be interpreted? For instance, can an established and consistently applied long-term practice qualify as a pension scheme, even in the absence of a formal written policy or documented scheme? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/04 - Guidelines on sound remuneration policies under CRD (repealing EBA/GL/2015/22)
  • ID: 2025_7494
  • Topic: Remuneration
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

EBA Remuneration Diversity Benchmarking - R23.00 - Reporting of not applicable (n/a) gender pay gap

What should be reported in template R23.00 if the gender pay gap cannot be calculated?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2025_7407
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

Discretionary pension benefits

Proportionate regular pension contributions on top of the mandatory regime are cited as an example of routine employment packages in the definitions section of the EBA Guidelines on sound remuneration policies under CRD (EBA/GL/2021/04) (“EBA Guidelines”). How large may such annual pension contributions be — whether in monetary terms or as a percentage of the staff member’s total annual remuneration — for the benefit to be considered proportionate and, provided that other criteria are met, qualify as a routine employment package (and therefore as fixed remuneration)? Does the size or other characteristics of the institution influence the assessment of whether a pension benefit is proportionate or routine? More broadly, what factors typically affect this assessment — for instance, do national industry-level remuneration benchmarks or the remuneration level within a specific institution play a role?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/04 - Guidelines on sound remuneration policies under CRD (repealing EBA/GL/2015/22)
  • ID: 2025_7492
  • Topic: Remuneration
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

Determination of exposure value cap for netting sets subject to a margin agreement.

Article 274(3) states "The exposure value of a netting set that is subject to a contractual margin agreement shall be capped at the exposure value of the same netting set not subject to any form of margin agreement". This wording has slightly diverged from Basel CRE52.2 which stated "The EAD for a margined netting set is capped at the EAD of the same netting set calculated on an unmargined basis".  Basel focused on applying the unmargined methodology in the wording not that it should be treated as if there were no margin agreement. This nuance in wording is leading to a misinterpretation of the CRR which is exacerbated by EBA Q&A 2023_6962 which has allowed for firms to apply SA-CCR in a manner which significantly underestimates capital requirements vs economic exposure. In situations where firms are posting excess variation margin which has a real economic credit risk to the counterparty the wording of the CRR and the Q&A implies that this can be fully disregarded from the exposure calculation. This would therefore mean that firms are able to arbitrage the capital rules and avoid capital charges by lending money to counterparties by posting it as variation margin under a CSA and then disregarding that exposure by applying the "unmargined" cap. This needs to be resolved by a clarification to the EBA Q&A to the effect that any collateral posted/received under a variation margin CSA should still be included in the exposure calculation, albeit using the unmargined rather than margined formulation to achieve the effect that the cap is designed to do per Basel CRE52.2 FAQ1.  i.e. this could easily be interpreted that if you are not subject to a margin agreement then anything which was variation margin should now just be characterized as NICA as it still economically exists as collateral. This would satisfy both the purpose of the rule and avoid the risk of understatement of capital requirements.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7478
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

Additional liquidity outflows corresponding to collateral needs resulting from the impact of an adverse market scenario.

Pursuant to Article 423(3) of Regulation (EU) No 575/2013, institutions are to add an additional outflow corresponding to collateral needs that would result from the impact of an adverse market scenario on the institution's derivatives transactions if material.  Should this be extended to include financing transactions if an outflow corresponding to collateral needs from the impact of an adverse market scenario is deemed material by an institution?

  • 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: 2025_7469
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

Whether the derogation under Article 119 (5) of CRR can be applied in the context of Article 395(1) of CRR

According to article 119 (5) of CRR, exposures to financial institutions shall be treated as exposures to institutions when calculating risk weighted assets for credit risk. Is article 119(5) applicable for the purpose of calculating large exposure limits in accordance with Article 395 of CRR? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7453
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

Interpretation of the treatment of covered bonds under the large exposures' regime in accordance with Article 395 of the CRR and the possibility of exposure reduction pursuant to Article 399 of the CRR.

Can covered bonds used as collateral in repo transactions, which are issued by the borrower (self-issued covered bonds), be considered eligible for exposure reduction under the large exposures regime in accordance with Article 399 of the CRR, taking into account the current interpretation of Article 207(2) of the CRR and Article 400(2) of the CRR, as well as the application of ECB Regulation (EU) 2016/445?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7436
  • Topic: Large exposures
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

Interaction between CRR3 article 124 and article 193

When should an IPRE exposure be riskweighted at 150% according to CRR3 article 124 para 1 (b)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7401
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

Calculation of risk-weighted exposure amounts for off-balance exposure in case of Unfunded Credit Protection (UFCP)

What is the correct treatment in cases where the consideration of CRM according to articles 235, 235a or 236 leads to higher calculated risk-weighted exposure amounts than those calculated without considering CRM, even when the risk weight of the protection provider is lower? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7357
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

Calculation of risk weights

How should institutions calculate a risk weight amended for credit protection in accordance with Chapter 4?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7356
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

Reporting of callable AT1, T2 and MREL/TLAC instruments

Should the AT1, T2 and MREL/TLAC instruments be assigned 0% ASF weight one year before potential call date or only once permission to redeem was granted by the competent authority?

  • 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_7275
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

application of condition specified in Article 501a. (1) o) after January 1, 2025

Are we correct that after January 1, 2025, during the examination of compliance with the ISF factor, it is necessary to examine point o) only in the case of exposures originated after January 1, 2025, and in the case of previous exposures originated before 1 January 2025 the debtor is not obligated to carry out any assessment?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7259
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

Level of EVE, NII and MV under Baseline scenarios reported positive for individual currencies (material or immaterial) in J1 report

Why is expected to always have the Level of EVE, NII and MV under Baseline scenarios reported positive for individual currencies (material or immaterial) in J1 report? Currently for the the rows of J1 report which reffer to Level of EVE, NII and MV under Baseline scenarios there is a validation rule (v16332_s) which throws a warning if the amount is negative regardless if the report is aggregated or for individual currencies. We believe this rule should be applied only for aggregated currencies and not for individual currencies as there could be a situation where the bank has a liability exposure in a specific currency which will end as a negative level of EVE/ NII or MV but when the aggregated report is obtained the final values are positive. Also, if the current rule is maintained, the results from J3 report will not be consistent with the ones from J1 as the negative amounts have to be reported positive. 

  • 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_7329
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as Rejected Q&A: 26/06/2025