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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

Deduction of pledged own shares from Common Equity Tier 1 items

Institutions, in the context of private banking and or corporate banking business, provide liquidity to investor/clients for purposes of their own commercial business (unrelated to the acquisition of the institution’s own shares). This is carried out by providing loans pledged with financial collateral in the form of equity shares, corporate bonds, sovereign debt, term deposits or cash in a sight account. Under the contractual arrangements of the loan and the pledge, as well as applicable legal regulation in our jurisdiction, in the event of default of the obligor the institution is not allowed to foreclose the financial collateral. Instead, it is allowed to sell the collateral in the market and seize the proceeds. However, the institution is only allowed to sell collateral in the amount that is required settle the debt of the obligor, no more. Financial collateral is valued daily and therefore the institution can sell it in the market until the debt is settled in full. Accordingly, the amount of the synthetic holding should be the accounting value of the pledged shares limited by the limit of the EAD of the loan. We present below two scenarios where there is overcollateralization. Scenario 1 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of the institution’s own equity shares in the amount of 150 shares that are valued in the market 1 monetary unit each, for a total amount of 150 monetary units.  The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares to settle the debt and therefore the deduction should be the accounting value of 100 shares as per Q&A 2020_5128. Is the approach followed by the institution, correct? Scenario 2 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of: 100 shares of the institution own shares that are valued in the market 1 monetary unit each, for a total amount of 100 monetary units. 100 shares of another company, for the purpose of the scenario is an industrial company, that are valued at 1 monetary unit each, amounting a total of 100 monetary units. The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares in total and would sell in the market the obligor’s portfolio prorate, i.e. 50 shares of the institution and 50 shares of the shares of the industrial corporate. Accordingly, the deduction would be the accounting value of 50 shares of the institution, in line with Q&A 2020_5128. Is the approach followed by the institution, correct?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7584
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/11/2025

Deduction of pledged own shares from Common Equity Tier 1 items

Institutions, in the context of private banking and or corporate banking business, provide liquidity to investor/clients for purposes of their own commercial business (unrelated to the acquisition of the institution’s own shares). This is carried out by providing loans pledged with financial collateral in the form of equity shares, corporate bonds, sovereign debt, term deposits or cash in a sight account. Under the contractual arrangements of the loan and the pledge, as well as applicable legal regulation in our jurisdiction, in the event of default of the obligor the institution is not allowed to foreclose the financial collateral. Instead, it is allowed to sell the collateral in the market and seize the proceeds. However, the institution is only allowed to sell collateral in the amount that is required settle the debt of the obligor, no more. Financial collateral is valued daily and therefore the institution can sell it in the market until the debt is settled in full. Accordingly, the amount of the synthetic holding should be the accounting value of the pledged shares limited by the limit of the EAD of the loan. We present below two scenarios where there is overcollateralization. Scenario 1 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of the institution’s own equity shares in the amount of 150 shares that are valued in the market 1 monetary unit each, for a total amount of 150 monetary units.  The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares to settle the debt and therefore the deduction should be the accounting value of 100 shares as per Q&A 2020_5128. Is the approach followed by the institution, correct? Scenario 2 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of: 100 shares of the institution own shares that are valued in the market 1 monetary unit each, for a total amount of 100 monetary units. 100 shares of another company, for the purpose of the scenario is an industrial company, that are valued at 1 monetary unit each, amounting a total of 100 monetary units. The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares in total and would sell in the market the obligor’s portfolio prorate, i.e. 50 shares of the institution and 50 shares of the shares of the industrial corporate. Accordingly, the deduction would be the accounting value of 50 shares of the institution, in line with Q&A 2020_5128. Is the approach followed by the institution, correct?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7585
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/11/2025

Deduction of pledged own shares from Common Equity Tier 1 items

Institutions, in the context of private banking and or corporate banking business, provide liquidity to investor/clients for purposes of their own commercial business (unrelated to the acquisition of the institution’s own shares). This is carried out by providing loans pledged with financial collateral in the form of equity shares, corporate bonds, sovereign debt, term deposits or cash in a sight account. Under the contractual arrangements of the loan and the pledge, as well as applicable legal regulation in our jurisdiction, in the event of default of the obligor the institution is not allowed to foreclose the financial collateral. Instead, it is allowed to sell the collateral in the market and seize the proceeds. However, the institution is only allowed to sell collateral in the amount that is required settle the debt of the obligor, no more. Financial collateral is valued daily and therefore the institution can sell it in the market until the debt is settled in full. Accordingly, the amount of the synthetic holding should be the accounting value of the pledged shares limited by the limit of the EAD of the loan. We present below two scenarios where there is overcollateralization. Scenario 1 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of the institution’s own equity shares in the amount of 150 shares that are valued in the market 1 monetary unit each, for a total amount of 150 monetary units.  The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares to settle the debt and therefore the deduction should be the accounting value of 100 shares as per Q&A 2020_5128. Is the approach followed by the institution, correct? Scenario 2 The institution grants a loan with the arrangements described above in the amount of 100 monetary units for the financing of the obligor’s commercial activity and the obligor pledges financial collateral in the form of: 100 shares of the institution own shares that are valued in the market 1 monetary unit each, for a total amount of 100 monetary units. 100 shares of another company, for the purpose of the scenario is an industrial company, that are valued at 1 monetary unit each, amounting a total of 100 monetary units. The institution would then calculate the amount of the deduction for the synthetic holding of its own shares considering that it can only seize 100 shares in total and would sell in the market the obligor’s portfolio prorate, i.e. 50 shares of the institution and 50 shares of the shares of the industrial corporate. Accordingly, the deduction would be the accounting value of 50 shares of the institution, in line with Q&A 2020_5128. Is the approach followed by the institution, correct?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7586
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 11/11/2025

Investment of funds received in exchange of e-money tokens

Do banks (credit institution) need to maintain segregated account to safeguard the proceeds from e-money token issuance?

  • Legal act: Regulation (EU) No 2023/1114 (MiCAR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7591
  • Topic: Other MiCAR topics
  • Date of submission:
  • Published as Rejected Q&A: 11/11/2025

LCR treatment of cashier’s cheques

What should be the correct LCR representation of a cashier’s cheque in terms of outflow rate and ITS category according to the C73 template? Is it appropriate to consider the amount net of the collateral posted?

  • 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_7530
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 10/11/2025

Delimitation of the quantity of liabilities and capital instruments to be computed in the NSFR calculation

In the context of Article 428o(a) CRR, which lists liabilities and capital items subject to a 100% available stable funding (ASF) factor, how should the reference to “before the adjustments required pursuant to Articles 32 to 35, the deductions pursuant to Article 36 and the application of the exemptions and alternatives laid down in Articles 48, 49 and 79” be interpreted? Specifically, should: the Common Equity Tier 1 (CET1) items be included in full, before all adjustments, deductions and exemptions referred to in Articles 32 to 35, 36, 48, 49 and 79; or the CET1 items be taken before adjustments pursuant to Articles 32 to 35, but after the deductions defined in Article 36 and the exemptions and alternatives laid down in Articles 48, 49 and 79?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7577
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 10/11/2025

Customers short sales internally matched with other clients’ long positions, as part of primary brokerage services

What is the expected treatment in the Liquidity Coverage Ratio of an internalized transaction, maturing within 30 calendar days, where the institution grants a margin loan to a client against a collateral that does not qualify as liquid assets and where this collateral is lent to another client to cover short sales?

  • 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_7595
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 10/11/2025

Whether to Include in the Scope of C 10.00 Portion of IRB Exposures that are guaranteed by Guarantors that are to be treated under SA

Could EBA provide guidance on whether to present in template C 10.00 the portion of an IRB treated exposure that has been secured by an eligible guarantee which becomes an SA treated exposure as a result of a CRM/substitution effects?  

  • 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_7373
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 31/10/2025

Identification of the part of the exposure not covered by the lien on the property

To identify the part of a non-ADC-exposure that shall be treated as stated in Article 124(1), which amount of the exposure has to be compared to the nominal amount of the lien?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7311
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/10/2025

Mixing approaches (loan-splitting, ETV) for real estate exposures collateralised by multiple immovable properties

Is it allowed to split an exposure/loan into using different riskweighting methods (loan-splitting vs ETV) in case they are collateralised by multiple immovable properties with different characteristics?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7296
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/10/2025

Calculating ETV in case of a broken sequence of mortgages

Is it allowed to distribute the property value (V) of the ETV formula in case the sequence of mortgages is broken to achieve optimal results for the individual ETV-ratios?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7294
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/10/2025

CRR3 - ETV calculation

With the CRR3 application, can you please confirm us the way to calculate the ETV ratio?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7175
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/10/2025

Treatment of Subscription Agreements in CIUs as Off-Balance Sheet Item

Clarification is sought on the prudential treatment of subscription agreements entered into for the acquisition of units in Collective Investment Undertakings (CIUs), specifically in the context of off-balance sheet exposures under Article 111(4) of the Capital Requirements Regulation (CRR). More specifically, clarification is sought on the treatment of subscription agreements upon signing of the relevant documentation but which effects, at the time of signing, is subject to the verification of conditions precedent (these conditions normally being out of the control of the subscriber) such as the relevant fund reaching a certain size.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7508
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/10/2025

Computation of the operational risk valuation adjustment after entry into force of Regulation - EU - 2024/1623

To comply with article 105, point (10) of CRR, and with article 17 of the Delegated Regulation  2016/101 we ask the following two questions:  Does the calculation of own funds requirements for operational risk in accordance with Title III of Part Three of CRR include operational risk relating to valuation processes? If the answer to the question above is yes, does the Delegated Regulation 2016/101 allow to avoid double counting of operational risk relating to valuation processes?

  • 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: 2025_7506
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 30/10/2025

Validation rules taxonomy V4.0 C06.02, v23688_s

The EBA Validation rules taxonomy v23688_s seems not relevant.  

  • 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_7543
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2025

C02 Own Funds Requirements CA2 - Row 0050 - inconsistent requirements for securitisation positions

The ITS for row 0050 states: "CR SA and SEC SA templates at the level of total exposures", information that hasn't changed between DPM 3.2 and DPM 4.0. The validation rule v0205_m with {tC_02.00.a, default: 0, interval: true}: {r0040} = {r0050} + {r0240} + {r0460} + {r0470} is inactive starting with 3/10/2025 and so far the securitisation positions reported on row0470 column 0010 were considered in the calculation of the row0040. Considering the ITS, are the securitisation positions from row 0470 requested on row0050 in regards of each column 0010 TREA and 0020 S-TREA?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7559
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 28/10/2025

CoRep Reporting C07.00 Template - Clarification regarding Default in Equity Exposures

The COREP template C07.00 requires institutions to report all counterparties treated under the Standardised risk weight approach to be split by Asset Class. These 'Asset Classes' are defined under Article 112 of CRR. The template clearly calls out that for the 'Exposure in Default' Asset Class, any exposure that is not subject to 'Equities' (under Article 133) should be included, hence the Equities exposures positions are not reported under Exposure in Default Asset Class.  The COREP template has a specific section to report Default in Equity Exposures – Row 0015. However, there is no definition of Equity Exposures at Default from a standardized risk weight perspective, hence we are seeking clarity on how this should be managed/disclosed. For example, we are now needing to disclose counterparties that have had loan restructuring and as part of this, equities have been issued and hence, this is where the Equity exposure position is classified as default.   

  • 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_7534
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

CoRep Template C07.00 - Clarification on “of which: Exposures to central banks”

As part of COREP template C07.00, Banks are required to disclose counterparties subject to Standardised risk weight split by Asset Classes such as 'Central Government or Central Banks', 'Regional Government', 'Public Sector Entities'. The template also requires additional data points to be disclosed including “of which: Exposures to central banks” – Row no. 0011. The COREP guidance for the above Row 0011 refers Article 112 (a) of CRR. However this article refers to Asset Class as “Exposures to Central Government or Central Banks”. This leads to an ambiguity in the disclosure. The firm is currently disclosing only exposures to 'Central Banks' even though the article reference is to Exposure to Central Government or Central Banks. We seeking to confirm the treatment to be applied. 

  • 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_7535
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025

Reporting of losses from lending collateralised by immovable property (C_15.00)

For loans secured by real estate property with any of the credit history scenarios below, should losses, and in case of scenario iii., exposures, be reported in COREP template C 15.00?  If yes, for which default event or events should the estimated losses be included in the reporting (i.e. is it correct to assume that under scenario ii. only losses estimated for the last default event in the reporting period should be included)?  Also, which default event should be used as a reference date for the reported exposures under scenario i. (the reporting period or the year prior to it) and under scenario ii. (exposure value at the first or at the last default event during the reporting period)? i. scenario:  The loan secured by real estate property had defaulted in a year prior to the reporting period, subsequently it exited/cured from the default state in the reporting period, but later it defaulted again during the same reporting period, and it stayed in the default state until the end of the period. ii. scenario:  The loan secured by real estate property had defaulted in the reporting period, later it exited/cured from the default state in the same reporting period, but still in the same period it defaulted again and stayed in the default state until the end of the period. iii. scenario: The loan secured by real estate property had defaulted in the reporting period and subsequently in the same period the institution stopped recognising the real estate property as CRR-eligible collateral (the real estate property ceased to meet the eligibility criteria).

  • 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_7540
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 27/10/2025