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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

Financial Sector Entity qualification for entity that assumes a loan in order to acquire an aircraft asset which then enters into a financial leasing agreement with an airline / aircraft operator

Should an entity that assumes a loan in order to acquire an aircraft asset which then enters into a financial leasing agreement with an airline / aircraft operator be treated as object finance / specialised lending or does it in addition need to be viewed as an exposure to a financial institution (and therefore a financial sector entity (FSE)) given the entity enters into a finance leasing arrangement that is an activity set out in point 3 of Annex I of Directive 2013/36/EU?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7120
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 28/03/2025

Treatment of leasing residual values under the standardized approach for credit risk

May the ‘’1/t*100%* residual value” formula introduced by CRR article 134.7 for the risk-weighted exposure amounts be applied to all leasing residual values? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7195
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 27/03/2025

Recognition of non-transferable liquidity held by and arising in third country subsidiaries in the context of the calculation of the consolidated LCR

What is the (combined) treatment of liquid assets held by and liquidity inflows arising in third country subsidiaries being subject to transfer restrictions for the purpose of the calculation of the LCR at consolidated level?

  • 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_7375
  • Topic: Liquidity risk
  • Date of submission:
  • Published as Rejected Q&A: 27/03/2025

Calculation of GAR - Template 8 of ESG Templates Pillar 3

How should we correctly compute the GAR (%) stock and flow?

  • 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: 2024_7227
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 27/03/2025

EBA publication on hard test results

Does EBA plan to publish information related to loss rates for immovable property markets in third countries? If yes, when is such a publication to be expected and which third countries will be covered?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7197
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 27/03/2025

Prudential treatment of goodwill and other intangible assets arising from the acquisition of an asset manager by an insurance undertaking fully owned by a bank

For the purposes of a deduction under Articles 36(1)(b) and 37 of the CRR, should a bank, which owns 100% of an insurance undertaking which acquires a controlling shareholding in an asset manager, deduct goodwill and other intangible assets (Article 4(1)(113) and (115) of the CRR) generated by the acquisition carried out by its insurance undertaking subsidiary?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7349
  • Topic: Own funds
  • Date of submission:
  • Published as Rejected Q&A: 27/03/2025

Table F12.01 – Movements in allowance and provisions for credit losses

Considering the greyed out columns in row 350 and 550: How can the actual movement of impairment be reflected correctly?

  • 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_7365
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as Rejected Q&A: 25/03/2025

MREL-REPORTING OF THE IMPACT OF GENERAL PRIOR PERMISSION

With regard to the unused amounts of the general prior permission which are to be deducted from the MREL capacity from the moment the authorization is granted by the authority, in terms of MREL-TLAC reporting, the Bank would like to have a confirmation of its interpretation of the instructions on how to report the unused part of the GPP plafond in M01.00 (ANNEX II REPORTING ON THE MINIMUM REQUIREMENT FOR OWN FUNDS AND ELIGIBLE LIABILITIES) . 

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/763 – ITS with regard to the supervisory reporting and public disclosure of MREL
  • ID: 2024_7198
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as Rejected Q&A: 25/03/2025

COREP C32_01 Fair Value changes of hedged items can be negative

Guidance for Row 120  of template C32.01 of EBA Framework Annex II Reporting on own funds and own fund requirements states that for Fair value changes of the hedged items in portfolio hedge of interest rate risk the amount of row 250 of template F01.01 should be inserted. However this row can contain a negative value and can be related to positions not in the trading book. In this case, when we comply with the instructions, submitting C32.01 is not possible since we get an error message that for row 0120 column 0090 is not smaller than row 0080. This is due to the fact that row 0120, col 0080 is a negative amount which corresponds as instructed with FINREP F01.01 row 250. Since it does not relate to positions in the trading book, row 0120, col 0090 is 0 and hence contains a bigger value.    

  • 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_7171
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 25/03/2025

Signage of Model Risk Fair Value Adjustments reported in C32.02 (v6575_s)

Model Risk FVAs taken due to market or product factors not captured by a valuation model can be either positive (resulting in a P&L loss) or negative (resulting in a P&L gain).  Where the adjustment would result in a P&L gain, it should logically be populated with a negative value. However, validation rule v6575_s states that FVAs reported must be greater than or equal to zero. Please confirm if Model Risk FVAs resulting in a P&L gain should be reported with negative signage in column 0190 of the COREP C32.02 template.

  • 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: 2024_7170
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 25/03/2025

Reporting signage of Concentrated Position Size and Market Value in C32.04 (v7301_s)

Concentrate Position Size and Market Value can be negative depending on factors including direction of underlying positions (long or short).  Please confirm reporting signage for Concentrated Position Size (col 0040) and Market Value (col 0060) in COREP template C32.04.

  • 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: 2024_7169
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as Rejected Q&A: 25/03/2025

Digital tokens representing ownership of a physical portion of gold

Should a digital token that represents ownership of physical portions of non-specific gold bars be qualified as an asset-referenced token according to Article 3(1)(6) of MiCAR?

  • Legal act: Regulation (EU) No 2023/1114 (MiCAR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7114
  • Topic: Classification of crypto assets (MiCAR)
  • Date of submission:
  • Published as Rejected Q&A: 21/03/2025

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
  • ID: 2024_7237
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 20/03/2025

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
  • ID: 2024_7202
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 20/03/2025

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
  • ID: 2024_7209
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 20/03/2025

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
  • ID: 2025_7322
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 20/03/2025

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
  • ID: 2025_7321
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 20/03/2025

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
  • ID: 2025_7319
  • Topic: Concentration risk
  • Date of submission:
  • Published as Rejected Q&A: 19/03/2025

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
  • ID: 2024_7186
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 19/03/2025

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
  • ID: 2025_7310
  • Topic: Other DORA topics
  • Date of submission:
  • Published as Rejected Q&A: 17/03/2025