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

Definition of "official export credit agency" for the calculation of deduction for non-performing exposures

Article 47c(4a) of the CRR exempts the part of a non‑performing exposure guaranteed or insured by an “official export credit agency” (ECA) from the deduction requirements laid down in Article 47c. However, the CRR does not define the term “official export credit agency”. In this context, what are the criteria for qualifying as an “official export credit agency” and how can it be determined whether an export credit agency and the guarantee or insurance provided meets the criteria for applying the derogation as provided in CRR Article 47c(4a)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7818
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 12/05/2026

Treating lease exposures as collateralised under the F-IRB approach

Is a permission of the competent authority under Article 199(6) of the CRR required for treating lease exposures as collateralised under the F-IRB approach if the lease object corresponds to other physical collateral?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7712
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/05/2026

Application of Article 199(6)(d) for low default portfolios

In cases where institutions do not have a sufficient internal track record of default and liquidation events due to the low-default nature of certain portfolios, is there an alternative approach, such as the use of relevant external data, market evidence, or a combination of internal and external information, that could be considered acceptable to demonstrate compliance with Article 199(6)(d) for eligible physical collateral?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7806
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 11/05/2026

Incorporation of historical data from integrated entities when historical information is not representative of current underwriting standards

Should an institution incorporate historical default data from acquired or merged entities into its IRB model estimates for PD, LGD, and CCF when calculating RWA for the acquiring institution’s exposures originated before and after the merger? 

  • 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: 2026_7701
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 31/03/2026

Assigning risk-weight to a credit facility where the drawdown is contingent on non-credit risk related conditions that are required to be met by the obligor prior to any initial or subsequent drawdown and where the conditions for the drawdown are not met.

What risk-weight should be assigned to a credit facility where the drawdown is contingent on non-credit risk related conditions that are required to be met by the obligor prior to any initial or subsequent drawdown and where the conditions for the drawdowns are not met per the reporting date?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7722
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 13/03/2026

Definition of Default (CRR Article 178) – Application of contagion and the 20% “significant part” threshold in the presence of joint credit obligations where default is applied at facility level

When the Definition of Default for retail exposures is applied at facility level, how should institutions apply the contagion and pulling effects set out in Article 178 CRR and EBA/GL/2016/07 in the presence of joint credit obligations, given that paragraphs 96–99 are articulated for obligor level default, while Article 178 CRR allows default recognition at facility level. In particular: Should a joint obligor (i.e. a specific set of obligors jointly liable) be treated as a separate obligor for the purposes of assessing contagion and the “significant part” (20%) threshold? How should contagion be assessed between:  joint credit obligations of the same set of obligors, individual exposures of the obligors participating in the joint obligation, and other joint credit obligations of those individual obligors with different counterparties, where default is recognised at facility level (including defaults identified through indications of unlikeliness to pay)? How should this be applied in practice for the 3 illustrative examples given?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/07 - Guidelines on the application of the definition of default under Article 178 CRR
  • ID: 2026_7736
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 10/03/2026

Clarification on the application of Article 215.2(b) of the CRR

Can guarantees issued by a central government for residential mortgages, that covers losses resulting from the non-payment of interest and other types of payments which the borrower is obliged to make, be used for unfunded credit protection if the final guarantee value is determined based on the residual value between an executive sale of underlying residential mortgage collateral and a max guaranteed amount?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7666
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 27/02/2026

Calculation of the unmargined exposure value for a netting set with multiple margin agreement or including both transaction subject to a margin agreement and transaction not subject to a margin agreement

How to calculate the capped exposure value, i.e., the exposure value of the netting set in the event that it is not subject to any type of margin agreement, when there are multiple margin agreements applicable to this netting set or when this netting set includes both transactions subject to a margin agreement and transactions not subject to a margin agreement? For the calculation of the unmargined value, should all deals be included in a single sub-netting set (the one containing contracts not subject to margining) and not divided as required by paragraph 4 of Article 274, or should the sub-netting sets remain separate and their value be calculated as if they were unmargined?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7649
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 26/01/2026

Inconsistency in the formulation of conditions for Hard Tests

Can Art. 199 para. 3, para. 4 CRR be interpreted in line with amended Art. 125 para. 2 sub-para. 3 and para. 3 sub-para. 1 6, 126 para. 2 sub-para. 3 and para. 3 sub-para. 1, 199 para. 4a CRR; hence, is it sufficient that a member state’s competent authority publishes loss rates despite different wording in Art. 199 para. 3, 4 CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7437
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 26/01/2026

Use of short-term issuer credit assessments under Article 131

May short-term issuer ratings be used to derive risk weights for unrated short-term exposures in the context of Article 131 CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7687
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 26/01/2026

Alternative treatment and SME support factor

If an institution uses the alternative treatment i CRR3 article 230 (4), does the exposure then qualify to use the SME supporting factor?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7682
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/01/2026

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

Umgang mit unwiderruflichen Zeichnungszusagen für Fondsanteile im Kreditrisiko Kurzbeschreibung: Zuordnung und Risikogewichtung von Zeichnungszusagen in den Phasen der Fondsauflegung

Im Rahmen der Abbildung unwiderruflicher Zeichnungszusagen für Fondsanteile in unserem Spezialfonds stellen sich uns folgende Fragen:1.    In welcher Forderungsklasse des Kreditrisikos nach 575/2013 der CRR (CIU gem. Art. 132 oder Unternehmen gem. Art. 122) sind unwiderrufliche Zeichnungszusagen während der Phase 3(Auflegung des Sondervermögens) sowie während der Phase 4 (nach Auflegung des Sondervermögens) zuzuordnen?2.    Mit welchem Risikogewicht sind diese Zusagen in den jeweiligen Phasen zu bewerten? 

  • 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: 2025_7582
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 02/12/2025

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