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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

Validation rules taxonomy V4.0 C07.00

The EBA Validation rules taxonomy v23005_m seems not relevant

  • 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_7475
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 26/09/2025

Credit Conversion Factor Treatment - Loan Participation Agreements in Unconditionally Cancellable Facilities

For loan participation arrangements where Bank A (the issuing bank) originates loans classified as unconditionally cancellable and applies 0% Credit Conversion Factor (CCF) under CRR Article 111, what is the appropriate CCF treatment for Bank B as the participating bank?Specifically, should Bank B apply:- a 0% CCF - consistent with the unconditionally cancellable nature of the underlying loans issued by Bank A- Standard CCF rates (20% or higher) - based on the participation agreement structure, where Bank B cannot directly exercise the unconditional cancellation rights?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions
  • ID: 2025_7505
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 15/09/2025

Application of real estate valuation principles to AIRB

Are the valuation principles per CRR 229.1(e) (capping to 6/8-year averages) applicable when using own estimates of LGD (AIRB)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7405
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 02/09/2025

Clarification Request on Eligibility of Agricultural Land and Forests as Collateral for RWA Purposes under CRR

Dear Sir/Madam, We are seeking clarification regarding recent changes introduced by the EBA concerning the eligibility of agricultural land and forests as collateral for the purposes of calculating Risk-Weighted Assets (RWA) under the CRR framework. According to the updated EBA interpretation, agricultural land and forest land may be treated as eligible collateral, provided they are insured. However, in Croatia, insurance coverage exists only for crops—not for the land itself. This creates a significant implementation challenge, particularly for forest land, which does not contain insurable crops at all, making it impossible to obtain the required insurance. In light of this, we kindly request clarification on the following points: Can agricultural or forest land be treated as eligible collateral under CRR if the required insurance cannot be obtained due to a lack of available insurance products in the local market? Does the absence of crop-related insurance for forest land entirely preclude its recognition as eligible collateral, even if it meets all other requirements (e.g. enforceability, valuation, and monitoring)? How should institutions proceed when collateral types are deemed eligible by the EBA but cannot be insured in practice due to market limitations? Is there flexibility within the CRR framework to accommodate cases where key eligibility conditions (such as insurance) are not achievable despite best efforts, or are alternative treatments available for such exposures? We would appreciate your guidance and any references to applicable CRR articles or relevant EBA Q&A that may clarify how to proceed in such cases.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 183/2014 - RTS for the calculation of specific and general credit risk adjustments
  • ID: 2025_7495
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 01/09/2025

Risk weighting attributed to gold in the form of a commodity such as jewellery items for pawn credit business

Pursuant to the new definition of gold bullion under Article 4(1)(60a) of CRR, can gold in the form of jewelry items taken as collateral in a pawn loan qualify as "gold" and thus be eligible for prudential treatment in accordance with Article 134 CRR for the value based on the gold content (purity × mass), with no allowance for artistic, numismatic, branding or other extrinsic attributes to such jewelry?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7491
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 01/09/2025

Can a receivable be identified as IPRE if a mortgage exists, but the securing property is not recognised as collateral?

Art. 124 para. 1 stipulates that banks receive a risk weight of 150% for IPRE receivables that do not fulfil all the conditions set out in para. 3. The question is what constellation of conditions must be met for this case to realistically materialise. An institution should normally be able to fulfil subsections a to d in para. 3. Paragraph 3 contains a reference to Article 208 and paragraph 1 of Article 229 in sub-item e. Article 229 paragraph 1 describes the property valuation and will not generally present institutions with insurmountable problems either. Article 208 begins with the statement that a property is only recognised as collateral if the following paragraphs 2 to 5 are fulfilled. One hurdle could possibly be the monitoring of the property value in accordance with paragraph 3. However, it is also conceivable that an institution will generally refrain from recognising real estate collateral due to an insignificant share in the portfolio. Can a receivable that is effectively secured by a mortgage be identified as an IRPE risk position without recognised real estate collateral, resulting in an RW of 150% under Art. 124 para. 1? Or does non-recognition also mean that the exposure is not to be regarded as collateralised (by a property) for the calculation of own funds and consequently receives the risk weight of an unsecured exposure?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7434
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 31/07/2025

Exposures to EU exchanges

Should exposures to EU exchanges be treated as exposures to institutions, under articles 119, 120 and 121?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7511
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 18/07/2025

Risk Weights for International Organisations under the Standardised Approach

Is it permissible that exposures to NATO Communication and Information Agency are assigned a 0 % risk weight under Article 118(f) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7411
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 18/07/2025

Determination of exposure value cap for netting sets subject to a margin agreement.

Article 274(3) states "The exposure value of a netting set that is subject to a contractual margin agreement shall be capped at the exposure value of the same netting set not subject to any form of margin agreement". This wording has slightly diverged from Basel CRE52.2 which stated "The EAD for a margined netting set is capped at the EAD of the same netting set calculated on an unmargined basis".  Basel focused on applying the unmargined methodology in the wording not that it should be treated as if there were no margin agreement. This nuance in wording is leading to a misinterpretation of the CRR which is exacerbated by EBA Q&A 2023_6962 which has allowed for firms to apply SA-CCR in a manner which significantly underestimates capital requirements vs economic exposure. In situations where firms are posting excess variation margin which has a real economic credit risk to the counterparty the wording of the CRR and the Q&A implies that this can be fully disregarded from the exposure calculation. This would therefore mean that firms are able to arbitrage the capital rules and avoid capital charges by lending money to counterparties by posting it as variation margin under a CSA and then disregarding that exposure by applying the "unmargined" cap. This needs to be resolved by a clarification to the EBA Q&A to the effect that any collateral posted/received under a variation margin CSA should still be included in the exposure calculation, albeit using the unmargined rather than margined formulation to achieve the effect that the cap is designed to do per Basel CRE52.2 FAQ1.  i.e. this could easily be interpreted that if you are not subject to a margin agreement then anything which was variation margin should now just be characterized as NICA as it still economically exists as collateral. This would satisfy both the purpose of the rule and avoid the risk of understatement of capital requirements.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7478
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

Interaction between CRR3 article 124 and article 193

When should an IPRE exposure be riskweighted at 150% according to CRR3 article 124 para 1 (b)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7401
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

Calculation of risk-weighted exposure amounts for off-balance exposure in case of Unfunded Credit Protection (UFCP)

What is the correct treatment in cases where the consideration of CRM according to articles 235, 235a or 236 leads to higher calculated risk-weighted exposure amounts than those calculated without considering CRM, even when the risk weight of the protection provider is lower? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7357
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

Calculation of risk weights

How should institutions calculate a risk weight amended for credit protection in accordance with Chapter 4?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7356
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

application of condition specified in Article 501a. (1) o) after January 1, 2025

Are we correct that after January 1, 2025, during the examination of compliance with the ISF factor, it is necessary to examine point o) only in the case of exposures originated after January 1, 2025, and in the case of previous exposures originated before 1 January 2025 the debtor is not obligated to carry out any assessment?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7259
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 08/07/2025

Validation rules taxonomy V4.0 C_10.00

The formulae of the control v23052_m seems incoherent

  • 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_7444
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C_08.01.a,C_08.02,C_09.02

The EBA Validation rules taxonomy v7551_m seems not relevant.

  • 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_7443
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C_08.01.a,C_08.02,C_09.02

The EBA Validation rules taxonomy v7549_m seems not relevant.

  • 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_7442
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C08.01/C08.02

The EBA Validation rules taxonomy v10667_m seems not relevant.

  • 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_7441
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C08.01/C08.02

The EBA Validation rules taxonomy v10666_m seems not relevant.

  • 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_7440
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C08.01/C08.02

The EBA Validation rules taxonomy v10664_h seems not relevant.

  • 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_7438
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025

Validation rules taxonomy V4.0 C_10.00

The formulae of the control v23053_m seems irrelevant

  • 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_7445
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 04/06/2025