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

High Earner data collections under CRD and IFD – Severance awarded during the financial year

Could you please modify the validation rule v09282_m in order to  exclude the « Severance payments awarded during the financial year » (r0200) from the ratio calculation of REM04 High Earners template ?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2014/07 - Guidelines on data collection exercise regarding high earners
  • ID: 2023_6884
  • Topic: Remuneration
  • Date of submission:
  • Published as Rejected Q&A: 16/10/2023

Validation Rule Asset Encumbrance (v11616_s)

Could the validation rule v11616_s be deactived in the same manner as for validation rule v4364_s? v11616_s: [F 32.01 (r0010;0020;0030;0040;0050;0060;0070;0080;0090;0100;0110;0120, c0030;0060;0080)] {{F 32.01}} >= 0 

  • 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_6881
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as Rejected Q&A: 16/10/2023

ASF carrying amount of hedge accounted fixed rate debt securities

According to the instructions of Annex XIII to Regulation (EU) No 2021/451, debt securities should be reported in C 81.00 based on their carrying amount (its book value). When the fair value hedge accounting is applied to fixed rate debt securities, the carrying amount is composed of principal, amortized cost and gain or loss reflecting the fair value of the hedged part of the liability. If rates have moved up, the carrying amount reduces and as consequence there is less available stable funding. This must be wrong, as rate changes do not increase nor reduce the bank’s available funding, but at maturity the carrying amount always equals the redemption amount. Should the fair value change for the hedge accounted funding, be ignored or reported separately on some cell where ASF would not decrease?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6762
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 16/10/2023

Contents of C03, row 0220 (Surplus(+)/Deficit(-) of CET1 capital considering the requirements of Article 92 CRR and 104a CRD)

The instructions for this memo item in C03 in Annex 2 of the ITS on Reporting (Regulation (EU) 451/2021) would need some clarification if one of the conclusions of Q&A 2016_2552 is considered.

  • 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_6671
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 16/10/2023

Actual or contingent obligations to purchase own CET1 instruments value

The deduction of direct holdings (1.1.1.1.4.1) will be based on the book value of the purchased equity shares similarly to Financial reporting, while the price used to value the share of the contingent obligation when purchasing our own CET1 instruments ( 1.1.1.1.5) is not clear if it should be on the nominal value, market value, book value shares valuation,…?

  • 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: 2022_6646
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 16/10/2023

materiality of Basis Risk

"Where the sum of floating rate instruments": Does the Sum refer to the 1)Net of reprining notional of Asset/Liability of floating rate instruments; or 2) Asset only ( as the denominator is 5% of assets), or 3)absolute value of Asset plus absolute value of Liability?  

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6862
  • Topic: Market risk
  • Date of submission:
  • Published as Rejected Q&A: 16/10/2023

Minority interests ( COREP & Net Stable Funding Ratio)

Are minority interests that arise from a subsidiary, which is a (Mixed) financial holding company in a third country and has obtained exemption for the prudential consolidation from the local regulator, eligible to inclusion in the EU parent entity consolidated? Can parent entity choose to apply CRR articles 84(2)/87(2) to exclude the minority interest of the subsidiary with potential negative equity ? What should be the treatment of the minority interest of the subsidiary with potential negative equity in the NSFR report of the parent entity?   

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6861
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 16/10/2023

Treatment of early repayment of the targeted longer-term refinancing operations (TLTROs)

Should a 0% outflow rate be applied to the cash outflow from the early repayment of the TLTRO facility by a bank, which will occur within 30 days?

  • 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: 2023_6857
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 16/10/2023

Can the reported amount in C76.00 r091, c010 be a negative value?

If an entity does not hold liquid assets in a particular currency (e.g. GBP), but does transact in that currency with various counterparts and incurs secured cash outflows, can the adjusted amount reported in C76.00 r091, c010 be a negative value?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/01 - Guidelines on LCR disclosure to complement the disclosure of liquidity risk management under Article 435 CRR
  • ID: 2023_6771
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 16/10/2023

Other retail deposits subject to higher outflow rates

Do the retail customers of financial institutions like challenger banks or fintechs whose clients specifically use mobile apps to sign up, log in, top up, use the features like payments, open savings accounts, invest, and etc comply with “an internet-access only account” definition? Is there a difference between customers who hold virtual cards and cannot access their funds via ATMs and the ones that have physical cards and can do so?

  • 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: 2023_6686
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 16/10/2023

Templates C01 and C04 Validation rule v4811_m

The v4811_m validation rule states that the control checks that the sum of IRB shortfall (-) of specific credit risk adjustments to expected losses (both defaulted and non defaulted exposures) in the C04.00 template (rows 0100 and 0145) must be equal to the row 0380 in template C01.00 - Own funds. Both factors of the formula, as described in the Instructions, do not cover the same scope and cannot be equal.

  • 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_6890
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 10/10/2023

Reporting of Interest from Central Bank Reserves in ALMM Maturity Ladder C66.01

Should interest from Central Bank Reserves be reported as inflows from Central Banks in the ALMM 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: 2023_6877
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 09/10/2023

C_81.00 ASF from capital items and instruments - Tier 2

It is written in article 428i (CRR2) that 'the amount of available stable funding shall be calculated by multiplying  the accounting value of various categories or types of liabilities and own funds by the available stable funding factors'. Concrete example: please give us the answer If credit institution has on balance sheet under Liabilities: (residual maturity for part of debt securities is more than 1 year and less than 5 years (2 000 000 eur) and other part has residual maturity more than 5 years) 1. Debt securities issued - 10 200 00 eur           1.1 Debt certificates - 10 000 000 eur           1.2 Interests payables on debt certificates - 200 000 eur   What amounts should be reported on NSFR C81.00 on row 0050, column 0030 - should it be 10 200 000 euros? Or amount is without interest - 10 000 000 euros? Or should it be equal to C01.00 row 0771 (where amortization is used for those debt securities that have residual maturity less than 5 years)? Also checked th Question: 2021_6016 - it does not give the aswer about the interests payables - should they be included or not?  

  • 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_6783
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 09/10/2023

Reporting of Template C_67.00 including Concentration of Funding by Counterparty.

Since there is no clear guidance on how the above item should be treated, we are requesting feedback on whether the EBA has taken stance on how deposits coming through Online Deposits Platforms should be classified in the Concentration of Funding by Counterparty, template C_67.00, and for liquidity purposes in general. In addition, we would be interested in understanding whether such treatment would differ for other purposes such as Financial Reporting – as an example, the bank in the above scenario indicated that these deposits are in fact covered by DGS, hence indicating that for this purpose the counterparty is the direct household.

  • 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: 2023_6778
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as Rejected Q&A: 09/10/2023

Validation rules: v7374_m, v7375_m and v7377_m

Can EBA confirm that the validation rules v7374, v7375 and v7377 satisfy with paragraph 114 of Commission Implementing Regulation (EU) 2022/1994 of 21 November 2022 for investor positions?

  • 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_6710
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 09/10/2023

Validation rule v7371_m and v7372_m

Paragraph 114 in Annex II to Regulation (EU) 2021/451 (ITS on Reporting) states that investors in securitisation positions should report among others columns 0310-0470 in C 14.01. Validation rule v7371_m and v7372_m expects column 0140 and 0230 to be filled in C 14.00 when column 0310 in C 14.01 is filled. We believe however that columns 0140 and 0230 in C 14.00 are only to be filled by originators/multi-sellers and not investors.

  • 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_6648
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 09/10/2023

Pillar 3 ESG Template 7 - Trading book

Should the Trading book be considered in the “Other assets excluded from the numerator for GAR calculation (covered in the denominator)”, as positioned under the EU Taxonomy template 1? Or should it be left in the “Other assets excluded from both the numerator and denominator for GAR calculation” category as in Pillar 3 ESG Template 7, leading to an inconsistency of reporting between the two templates?

  • 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: 2023_6809
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 09/10/2023

Template 10

The Annex II of the Commission Implementing Regulation (UE) 2022/2453 states that the Template 10 (“Other climate change mitigating actions that are not covered in Regulation (EU) 2020/852”) shall include “exposures of the institutions that are not taxonomy-aligned as referred to in Regulation (EU) 2020/852 according to templates 7 and 8 but that still support counterparties in the transition and adaptation process for the objectives of climate change mitigation and climate change adaptation. Those mitigating actions and activities shall include bonds and loans issued under standards other than the Union standards”. As a consequence, which of this two following options should institutions follow in order to select the Bonds and the Loans that shall be disclosed in Template 10? The Bonds and the Loans that the institution shall select to be disclose in the Template 10 are only those eligible according to the EU Taxonomy, but that are not taxonomy-aligned (i.e. Bonds and Loans that could not be covered in Template 7 or 8); The Bonds and the Loans that the institution shall select to be disclose in the Template 10 are both those eligible according to the EU Taxonomy, but that are not taxonomy-aligned and those that have been defined environmentally sustainable according to standards other than the European Union ones (i.e. Bonds and Loans that are not eligible).  

  • 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: 2023_6810
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 09/10/2023

ESG P3 - NACE sector breakdown in Pilar III reporting (templates 1 and 5 and, partially 3)

Should NACE activity codes be consistent between FINREP and Pilar III ESG reporting, or can P3 ESG templates breakdowns be adjusted to differ from FINREP but better align with sustainability linked info?   

  • 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: 2023_6821
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 09/10/2023

Display of provision during substitution approaches

Due to the future application of the CRR3, the used of the IRB model will be limited. As example, some expositions (Corporates SME especially) considered with IRB method (and so displayed in C08A – CR IRBA form in COREP), are currently guaranteed by an institution or a sovereign which are also today considered with the IRB method. With CRR3, the debtor will probably stay with the IRB method (so still displayed in CR IRBA form in COREP), but there will be an outflow to the CR SA because the Basel method of the guarantor will be standard model. There will be an inflow in CR SA to display the metrics of the expositions after taking into account the characteristics of the guarantor (CRM). Around September 2021, we asked to your team, some precision about the “display of the provision during the substitution approach” under the reference 2021_6220. Our question result from the Q&A 2017_3335 which confirm the possibility to apply the substitution approach when the exposure and the guarantor are treated by the institution under different basel methods. Our Q&A has been rejected considering that the issue it deals with is already explained in section 3.1.1 of Annex II to Regulation (EU) No 2021/451 (ITS on Supervisory Reporting). Without mistake of our part and conversely of your affirmation, we are still considering the display of the provision non taking into account by the Q&A 2017_3335. For reminder, the display of the provision in COREP forms is different according to the Basel method applied: The value is displayed in column 0020 of C07 - CR SA uses the Basel method of the debtor Inversely for the C08 - CR IRB, the value is displayed in column 0290 (as memorandum item) uses the Basel method of the guarantor (if there is any)

  • 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_6739
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 29/09/2023