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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.

List of Q&A's

ESG P3 - Template 10 - Scope of disclosure and any relation to GAR related templates (Template 6, 7 and 8)

In Template 10, is the disclosure of the data identified at the counterparty / entity-level or data is identified at the exposure level? Can EBA help to also clarify when an exposure is reported in Template 10, would it be required for reporting in Template 6, 7 and 8 (only for the taxonomy aligned portion)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

GAR template 7, row 25 Households

For GAR template 7, must the row 24 “households” be always strictly equal to the sum of rows 25 +26 + 27?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Template 7 - Reporting of Gross carrying amount in total assets

In template 7, should the gross carrying amount of total assets match FINREP or the gross carrying amount as defined by Delegated regulation EU 2021/2178, as asked by the ITS ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Classification as a “specialised debt restructurer” (SDR) pursuant to Article 36(5) of Regulation No 575/2013

To be classified as specialised debt restructurer in accordance with Article 36(5) of the Regulation No 575/2013 (CRR), an institution’s sight deposits must not exceed 5% of its total liabilities. How should the term “sight deposits” be interpreted in the context of the Article 36(5) of the CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Classification as a “specialised debt restructurer” (SDR) pursuant to Article 36(5) of Regulation No 575/2013

For how long prior to an institution’s classification as a specialised debt restructurer must all criteria specified in Article 36(5) of Regulation No 575/2013 be met by the institution?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Period to comply with the limit referred to in Article 37 regarding concentration risk and exposure value excess.

What limit does it refer Art. 38 (2) when it states that “Competent authorities may grant the investment firm a limited period to comply with the limit referred to in Article 37”? 

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Can the Article 122a adjustment be combined with the Article 501 SME-adjustment?

The Article 122a paragraph 3  letter c subletter ii CRR says, that if all the criteria are met, there can be a factor of 80 % applied. But it can't be combined with the 75 % adjustment of Artikle 501a. But can it be combined with the adjustment for SMEs due to Article 501?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Regulatory technical standards - subcontracting ICT services supporting critical or important functions

Where and when was the Comission Delegated Regulation (EU) supplementing Regulation (EU) 2022/2554 of the European Parliament and of the Council with regard to regulatory technical standards to specify the elements which a financial entity needs to determine and assess when subcontracting ICT services supporting critical or important functions as mandated by Article 30(5) of Regulation (EU) 2022/2554 oficially published? 

  • Legal act: Regulation (EU) No 2022/2554 (DORA)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Applicability of DORA and TFR requirements to VASPs

Do the requirements of the Digital Operational Resilience Act (DORA) and the Transfer of Funds Regulation (TFR) apply to Virtual Asset Service Providers (VASPs) that are not classified as Crypto-Asset Service Providers (CASPs) under the Markets in Crypto-Assets Regulation (MiCAR) as of December 30, 2024 and are benefiting from the MiCAR transition period?

  • Legal act: Directive 2022/2556/EU (DORA)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Applicability of Regulation (EU) 2022/2554 (DORA) to ICT services provided by financial entities.

Clarification is needed on whether financial institutions providing ICT services to other financial institutions – regardless of whether these services are ancillary to regulated financial activities – can be qualified as ICT third-party service providers under Regulation (EU) 2022/2554. If they are, must their contractual relationships comply with the mandatory provisions outlined in Article 30 of the mentioned Regulation or are these requirements inapplicable since such entities are already authorised/licenced/registered? 

  • Legal act: Regulation (EU) No 2022/2554 (DORA)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Remaining maturity of the transactions for collateralised transactions

As per CRR Article 162(2)(c)& (d)- This states (as per below). Can the term "remaining maturity" in the below paragraphs be defined as Margin Period of Risk for collateralised transactions and Contractual maturity for un-collateralised transactions? (c)  for exposures arising from fully or nearly-fully collateralised derivative instruments listed in Annex II and fully or nearly-fully collateralised margin lending transactions which are subject to a master netting agreement, M shall be the weighted average remaining maturity of the transactions where M shall be at least 10 days; (d)  for repurchase transactions or securities or commodities lending or borrowing transactions which are subject to a master netting agreement, M shall be the weighted average remaining maturity of the transactions where M shall be at least five days. The notional amount of each transaction shall be used for weighting the maturity;

  • 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

Treatment of Net Interest Income Stress Outlier Test (NII SOT) in scenarios where breaches occur due to one-off effects (EBA/RTS/2022/10)

Could you please provide guidance on how banks should approach the reporting of such NII SOT breaches arising from such short-term, non-structural events and in addition how is it foreseen that the regulator should govern such cases? Specifically, are there any provisions or considerations that can be applied to account for these temporary effects without misrepresenting the bank's overall NII sensitivity? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 530/2014 - RTS on materiality of thresholds for internal approaches to specific risk in the trading book

Exemption from approval for financial holding companies or mixed financial holding companies as per Directive 2013/36/EU (CRD) Article 21a (4) (d)

Should the criterion in Article 21a (4) (d) CRD (engagement in taking management, operational or financial decisions affecting the group or its subsidiaries) be considered to be met if the some persons are represented on the governing bodies of both the (mixed) financial holding company and an institution that is a subsidiary?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Template EU MR4 missing from Annex

The EBA Pillar 3 mapping tool mentions template EU MR4. I cannot find this in any of the annexes. Is this template relevant?

  • 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

Reported amount in F09.02 col0010 if overcollateralization can occur

How should financial guarantees be reported in F09.02 if the value of the guarantee exceeds the loan exposure (possible overcollateralization)?Example:There is a credit risk mitigation group including 2 financial guarantees and 1 loan exposure as follows:Financial guarantee nr.1 - 15 000 EURFinancial guarantee nr.2 - 17 000 EURLoan exposure - 14 000 EURReported amount in F09.02 col0010 = ?

  • 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)

Date of Disclosure

CRR Art. 433 states that the disclosure should happen the date of the publication of the financial statements. Due to the imlempentation of CRR III EBA granted an extention to submit Q1 regulatory reports to the 30.06. How should the disclosure be handled?

  • 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

EBA_v10862 (Type – Warning validation): Assets under custody ({G01.00,r0060,c0010}) should be equal to the value in FINREP ({F22.02,r0060,c0010}).

a) The “Custody assets” referred in FINREP 22.2 is described as “service of safekeeping & administration of financial instruments for the account of clients provided by the institution and services related to custodianship such as cash and collateral management”. How the word “Service” in above definition needs to be interpreted? Does it mean to populate balance only in those cases where some fee is being charged for services provided or record all custody assets irrespective of any fee is charged /revenue being generated? 21.2. Assets involved in the services provided (22.2)285. Business related to asset management, custody functions, and otherservices provided by the institution shall be reported using the followingdefinitions:(a) ‘Asset management’ shall refer to assets belonging directly to thecustomers, for which the institution is providing management. ‘Assetmanagement’ shall be reported by type of customer: collective investmentundertakings, pension funds, customer portfolios managed on adiscretionary basis, and other investment vehicles;(b) ‘Custody assets’ shall refer to the services of safekeeping andadministration of financial instruments for the account of clients providedby the institution and services related to custodianship such as cash andcollateral management. ‘Custody assets’ shall be reported by type ofcustomers for which the institution is holding the assets distinguishingbetween collective investment undertakings and others. The item ‘of which:entrusted to other entities’ shall refer to the amount of assets included incustody assets for which the institution has given the effective custody toother entities; b)    As the validation rule “V10862" matches 2 data points (AUM and Custody assets) which in GSIB is reported in one cell under table G01.00 Row 0060 “Assets under Custody” whereas in FINREP table 22.2 there are two different cells representing it “Assets Management(by type of customer) Row 0010” & “Custody assets (by type of customer) Row 0060” , thus making the validation incorrect? Hence, please clarify as to how to interpret the validation and whether it will be updated to include Asset Management and Custody Assets in FINREP 22.2 (i.e. validation will be Asset Management + Custody Assets in FINREP 22.2 to "Assets Under Custody" in GSIB) such that the number then reported will tie back with GSIB "Assets under custody”.

  • 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

Inclusion of expected loss for equity exposures in calculation of Expected loss amount reducing CET1

Are the expected loss amount for equity exposures calculated in accordance with Article 158(7), (8) or (9) CRR included in the impairment comparison according to Article 159 CRR or not? Shall the expected loss amount for equity exposures be deducted directly from Common Equity Tier 1 capital in row 380 of CA1 (in accordance with Article 36 (1)(d) CRR)? Even if as a consequence validation rule v4811_m would fail?

  • 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)

Validation Rule for Marginal Impact of Reintegration of CVA Exemptions

The guidance for the population of rows 0040-0110 specifies that firms should populate the marginal impact of reintegration of CVA exemptions "separately for each exemption". However there is a warning validation rule v23083_m which specifies that the sum of the individual exemptions should be equal to the total "{r0040} = {r0050} + {r0060} + {r0090} + {r0100} + {r0110}". We would like to query whether the validation rule is valid and therefore whether we should be calculating a single CVA exemption reintegration impact of excluded transactions and then attributing by type of exemption or genuinely calculating the marginal impact separately by type of exemption. 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions

Validation rules taxonomy V4.0 C09.02 v23650_h

According to the formulae v23650_h : {r0030} = {r0050} + {r0051} in c0010, c0030, c0040, c0050, c0055, c0060, c0070, c0105, c0110, c0120, c0121, c0122, c0125, c0130 in C09.02 “CR GB 2”.This control makes the comparative between r0030 “Corporates” and the sum of lines r0050 “Of Which: SME” and r0051 “Of Which: Large Corporates" in CR GB 2.However, in Annex 2, the instructions for line 0030 refer to Article 147(2), point (c), of Regulation (EU) No 575/2013 which classifies Corporates as the following : i)General Corporate, ii) Specialized financing exposures and iii)Purchased receivables. The control seems incoherent since lines r0050 and r0051 expect "of which" items.To be compliant with the corporate categories defined in Article 147, line 0030 should be compared with the totalization of lines 0052 "Specialized lending", 0057 "Purchased receivables" and 0058 "Others".Could you please therefore confirm that the control needs to be modified?

  • 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