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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

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

CRR3 - ETV calculation

With the CRR3 application, can you please confirm us the way to calculate the ETV ratio?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7175
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/10/2025

Treatment of Subscription Agreements in CIUs as Off-Balance Sheet Item

Clarification is sought on the prudential treatment of subscription agreements entered into for the acquisition of units in Collective Investment Undertakings (CIUs), specifically in the context of off-balance sheet exposures under Article 111(4) of the Capital Requirements Regulation (CRR). More specifically, clarification is sought on the treatment of subscription agreements upon signing of the relevant documentation but which effects, at the time of signing, is subject to the verification of conditions precedent (these conditions normally being out of the control of the subscriber) such as the relevant fund reaching a certain size.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7508
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 30/10/2025

Recognition of FX hedging on loan collateral value for volatility adjustments for currency mismatch

In case of a loan secured by financial collateral where the currency of the loan differs from the currency of the collateral, the FX risk is hedged by a financial instrument (cross-currency swap) which proceeds are pledged by the obligor to the lending institution. Such cross-currency swap hedge allows the lending institution to offset any loan collateral value decrease due to a depreciation of the collateral’s currency, thus neutralising any effect from the currency mismatch between the currency of the loan and the currency of the collateral. In this case, is it possible to assimilate for the purpose of article 223(1) of CRR that the collateral is denominated in the same currency as the loan (implying that no volatility adjustments for currency mismatch would apply) ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7532
  • Topic: Credit risk
  • Date of submission:
  • Published as Rejected Q&A: 16/10/2025

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