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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.

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List of Q&A's

Template 2 - EBA validation rules v89325_m and v89326_m

The formula linked to the following rule IDs: v89325_m and v89326_m appears to be incorrect

  • 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_7633
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 12/01/2026

Pillar 3 Template EULR2 - LRCom: Leverage ratio common disclosure (Row 24) Instruction

Pillar 3 Template EULR2 - LRCom: Leverage ratio common disclosure (Row 24) Instruction In the current instruction for Row 24, it states: “Sum of amounts in rows 7, 13, 18, 22, and EU-22k of EU LR2 – LRCom.” However, based on the latest EBA mapping table/logic, the correct reference should be: LRCom (sum of rows 7, 13, 18, 22, EU-22m). This aligns with our understanding that the correct row is EU-22m, not EU-22k. Could EBA please update the instruction accordingly?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR
  • ID: 2025_7620
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 12/01/2026

Clarification request - CP Pillar 3 ESG - Template 2 covered bonds

We are reaching out regarding the Consultation Paper published by EBA on 22/05 concerning Pillar III ESG disclosures. Specifically, we would kindly request clarification about the additional line required in Template 2 related to covered bonds: "In addition, a breakdown for information on cover pool of covered bonds is requested in rows for the Total EU area and Total non-EU area (rows 1.1 and 6.1 respectively)."   As stated in the CP document: “Following Recital 55 of the CRR3, the EBA is asked to assess means to enhance the disclosures on ESG risks of cover pools of covered bonds and to consider whether information on the relevant exposures of the pools of loans underlying covered bonds issued by institutions, either directly or through the transfer of loans to a special purpose vehicle (SPV), should either be included in the revised ITS or in the regulatory and disclosure framework for covered bonds”   We would appreciate your guidance on the following points: • Should only the covered bonds issued by the institution reporting the template be considered? Or does this also include covered bonds acquired from other institutions (other banks - in addition to the already mentioned SPVs)? • Considering the scope of the template, the exposures to be reported refer to the loans collateralized by the immovable properties securing the bonds, and not the value of the bonds themselves, is that correct? • Should the total amount be reconciled with a specific cell in the FINREP reporting framework?   Thank you in advance for your kind clarification.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7600
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 12/01/2026

Annual reporting for GSIIDISPILLAR3 to the Competent Authorities under DPM 4.2

Should the Reporting Framework 4.2 related taxonomy be considered for the 2025 end-of-year reporting for GSIIDISPILLAR3 ? Pursuant to the last corrections included in DPM 4.2 for the GSIIDISPILLAR3 templates, respectively the removal of the GSIB column in the Annotated Table Layout for GSIIDISPILLAR3 4.2 (all the greyed-out cells under the column 0009 indicating non-applicability and for which the datapoints were doubled in DPM 4.1), we kindly request the confirmation that the DPM 4.2 can be used for the 2025 end-of-year reporting.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1030/2014 - ITS on disclosure of values used to identify global systemically important institutions (as amended)
  • ID: 2025_7590
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 12/01/2026

FINREP Identical Cells 5458783, 5458788, 5459395, 5460187

Could the EBA confirm whether these identical cell checks are correct? If not, should they be updated to align with the previous logic (v8610_i, v8611_i, v10006_i, v10007_i) to ensure consistency between templates and definitions?Please clarify the intended scope of collateral reporting in these templates and whether the current rules will be revised.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7660
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 23/12/2025

FINREP Validation rules v23845_h, v23846_h, v23847_h

Could the EBA clarify the rationale for excluding rows 0015, 0185, and 0365 from the new validation rules for template F 12.01.a?This change creates inconsistencies with cross-template validation rules such as: v6030_m: {tF_12.01.a, r0010, c0100} - {tF_12.01.a, r0015, c0100} = {tF_04.03.1, r0180, c0050} + {tF_04.04.1, r0140, c0050} v6033_m: {tF_12.01.a, r0180, c0100} - {tF_12.01.a, r0185, c0100} = {tF_04.03.1, r0180, c0060} + {tF_04.04.1, r0140, c0060} v6036_m: {tF_12.01.a, r0360, c0100} - {tF_12.01.a, r0365, c0100} = {tF_04.03.1, r0180, c0070} + {tF_04.04.1, r0140, c0070} These rules assume that rows 0010, 0180, and 0360 include “Cash balances at central banks and other demand deposits.” Additionally, the items “of which: collectively measured allowances” and “of which: individually measured allowances” will no longer consider these balances because the related rules (v5054_m, v5055_m, v5056_m) reference rows 0010, 0180, and 0360 only. Could the EBA confirm whether this exclusion is intentional and, if so, provide guidance on how to reconcile these templates and validation rules?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7659
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 23/12/2025

Controls v4968_m, v5024_m, v5372_m, v5373_m and v5376_m

Please note that controls v4968_m, v5024_m, v5372_m, v5373_m and v5376_m should have the condition "eba_qAS:qx2004" instead of "eba_AS:x2" to comply with column 010 of row 010 of report F_00.01

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7655
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 23/12/2025

C_07.00 : columns 010 to 040 of line 210

I would like to point out that columns 010 to 040 of line 210 of report C_07.00 should have been ungreased in the EBA 4.2 taxonomy to be in accordance with the EBA's answer to question 2025_7348.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7654
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 23/12/2025

v7520_m_0

Please review v7520

  • 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_7502
  • Topic: Supervisory reporting
  • Date of submission:
  • Published as Rejected Q&A: 23/12/2025

v1672_m_0

Please review the correctness of this validation rule

  • 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_7501
  • Topic: Supervisory reporting
  • Date of submission:
  • Published as Rejected Q&A: 23/12/2025

“part of a group”

Does “part of the group” in the meaning of Art. 12 (2) IFR also include investment firms established in a third country?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7542
  • Topic: Capital requirements
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

Wording error in IFR/IFD regarding the method for calculating capital requirements for counterparty default risk (K-TCD)

Why is collateral posted to the counterparty ignored in the Exposure Value (EV) calculation for a cleared derivatives portfolio under a margin agreement with a negative Mark-to-Market?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7560
  • Topic: K-factor requirements
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

Calculation of dividend component at individual accounts of the institution

In the context of CRR article 314(2), should the dividend component (DC) at individual level include the dividends received from wholly owned subsidiaries?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7574
  • Topic: Operational risk
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

Obligations in Equity exposures of Article 133 (1) (c) (i) CRR

Does the term “obligation” in Article 133 (1) (c) (i) CRR refer to the principal amount, or does it also refer to the interest payment solely? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7631
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

Application of obligations relating to the default to ancillary services companies (such as operation leasing entities)

Is it necessary to apply in operating leasing entities the obligations of monitoring and controlling risks relating to the new definition of default (forbearance, early warning, etc.)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7515
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

Clarification on the relationship between Margin of Conservatism (MoC) and rating/calibration philosophy (PIT vs TTC) under EBA Guidelines on PD and LGD estimation (EBA/GL/2017/16)

According to the EBA Guidelines on PD and LGD estimation (EBA/GL/2017/16), the Margin of Conservatism (MoC) aims to address uncertainty arising from data and methodological deficiencies, changes in underwriting standards or risk appetite, and general estimation error. The Guidelines describe the three MoC categories (A, B, C) and the principles for quantification, but they do not explicitly refer to any link between MoC and the chosen rating philosophy (Point-in-Time vs Through-the-Cycle) or calibration philosophy. Could you please clarify whether the regulator expects the MoC concept to be aligned with the institution’s PIT/TTC philosophy, or whether MoC is entirely independent of the rating/calibration philosophy?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/16 - Guidelines on PD estimation, LGD estimation and the treatment of defaulted exposures
  • ID: 2025_7634
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

EBA publication of loss rates for Swiss residential and commercial property under CRR Articles 125 and 126.

Will the EBA publish loss rate data for Swiss residential and commercial property markets to enable institutions to apply preferential risk weights under Articles 125 and 126 CRR? If yes, what is the expected timeline?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7635
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

Calculation of the Exposure-to-Value (ETV) ratio and risk weighting when dealing with complex collateral structures

Under Articles 124, 125, and 126 of Regulation (EU) No. 575/2013 (CRR) as amended, how should institutions calculate the Exposure-to-Value (ETV) ratio and apply risk weighting when dealing with complex collateral structures involving multiple liens, syndicated financing, and mixed property types? Specifically: 1.      Is the exposure value defined in Article 111 the correct basis for determining the portion of exposure exceeding the lien amount? 2.      Should the ETV ratio be calculated only up to the nominal amount of the lien, or on the full loan amount? 3.      When a loan is secured by multiple properties, should the ETV be calculated as a single ratio using the aggregate property value, or should separate ETVs be calculated per lien/property? 4.      How should the gross exposure be adjusted when multiple first-ranking liens exist, some held by the institution and others by third parties? 5.      In syndicated loans where liens are shared pari passu among institutions, how should the exposure be compared to the nominal amount of the lien for risk weighting under Article 124(1)? 6.      In cases where the lien sequence is broken (e.g., junior liens held by third parties), is it permissible to distribute the property value across liens to optimise ETV ratios? 7.      Can an institution apply both the loan-splitting and ETV approaches to different parts of a single loan secured by multiple properties with varying characteristics (e.g., residential vs commercial)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7422
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 19/12/2025

Application of general requirements of Chapter 6 of the Regulation (EU) No 575/2013 regarding the definition of own funds

Does the definition of „own funds“ in Article 4(46) of PSD2 refer to the definition of „own funds“ as defined in point 118 of Article 4(1) of Regulation (EU) No 575/2013 only, or are Articles 26 - 88 of Regulation (EU) No 575/2013, in particular Articles 26 (3), 77 and 78 of Regulation (EU) No 575/2013, also refered to by Article 4(46) PSD2?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7396
  • Topic: Other topics
  • Date of submission:
  • Published as Rejected Q&A: 12/12/2025

Netting of foreign exchange derivatives (as per Annex (II, a-e) of Reg. No 575/2013) in Net Stable Funding Ratio (NSFR)

What criterion should be adopted for the treatment of a foreign-exchange derivative contract included in a netting set between what reported in Article 428d(4) and in Article 428d(2) of CRR2?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7625
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 11/12/2025