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.

List of Q&A's

Counterparty classification

On FINREP reports, each counterparty is classified into a counterparty type, like Household or Government. Some government services are provided by volunteers, which raises the question how this should be classified, since the people are technically not employed by the government. Examples include volunteer police or volunteer firefighters and their unions, whose members provide and/or facilitate services specific to governments.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Scaling of gross JTD amounts of securitisation tranches with a maturity less than one year

Should the tranche maturity (MT) of less than one year of gross JTD amounts of securitisation tranches resulting from either formula in Art. 257(1) CRR be floored at one year as required by para. 2 of this Article, or can the MT be used without this floor of one year in order to enable scaling, with a floor of three months, as prescribed by Art. 325z(5) CRR in conjunction with Art. 325x(3) CRR? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Definition of Delta GIRR risk-free interest rate curves

Which risk-free interest rate curves per currency should be considered as different curves? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Intragroup transactions in calculation of net positions and own funds requirements for FX risk

i)When calculating the entity level positions and own funds requirements under Article 325b(4), are intragroup transactions allowed to be included ? ii)Same question for Article 352(2) determination of consolidated structural position

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

ESG P3 - Template 1 - Reporting of column k (GHG emissions (column i): gross carrying amount percentage of the portfolio derived from company-specific reporting)

In Template 1, “column k (GHG emissions (column i): gross carrying amount percentage of the portfolio derived from company-specific reporting)”,  should the denominator used in the calculation of the percentage be: the gross carrying amount of exposures which GHG emissions are available or estimated  OR the gross carrying amount of all the exposures within the banking book portfolio regardless of whether the GHG emissions are available, estimated or not available (missing).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures

Operational risk – gross loss in tax related events in accordance with REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) No 575/2013 as regards requirements for credit risk, credit valuation adjustment risk, operational risk, market risk and the output floor, Article 318.

How should an institution calculate gross loss based on the regulatory changes stipulated in Article 318. of the Regulation amending Regulation 575/2013 in the following examples? Case 1 – Delayed tax payment, penalty interest payment, and system repairment expenses Case 2 – Delayed tax payment, no penalty interest payment, system repairment expenses.  Case 3 – Tax to be paid for this year and previous years, no penalty interest, or fine, financial reports for previous year to be revised and re-published.  Case 4 – Tax to be paid for this year and previous years, no penalty interest or fine, no changes to financial reports for previous year.  Case 5 – Tax to be paid for this year and previous years, penalty interest and fine, financial reports for previous year to be revised and re-published Case 6 – Tax to be paid for this year and previous years, penalty interest and fine, no changes to financial reports for previous year   

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Row 0820 of C 04.00

Row 0820 of C 04.00 - Own funds requirements related to Pillar II adjustments states that if a competent authority decides that an institution must calculate additional own funds requirements for Pillar II reasons, those additional own funds requirements shall be reported in this row. Two approaches could be considered:This row shall only be reported when Pillar II adjustments have been established as an amount instead of a ratio. This row shall always be reported:If Pillar II adjustments have been set as a ratio the amount to be reported is: P2R*RWA.If Pillar II adjustments have been set as an amount that figure shall be reported in row 0820 of C 04.00. Therefore, instructions do not establish which additional own funds requirements shall be reported.  Thus, which approach shall be followed to report row 0820 of C 04.00? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable

Part 2 – Template specific instructions to template B_06.01

Data point B_06.01.0050 is missing from the official ITS templates. Is this data point no longer applicable?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information

Template specific instructions – primary keys

How to report data fields in case of missing values?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information

Template specific instructions – field B_05.02.0060 (Identification code of the recipient of sub-contracted ICT services)

How to report data field B_05.02.0060 if the ICT third-party service provider is a direct provider (rank =1)?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information

Template specific instructions – field B_05.01.0020 (Type of code to identify the ICT third-party service provider)

How to report type of identification code in data field B_05.01.0020 when using codes other than LEI or EUID?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information

Template specific instructions – field B_02.02.0160 (Location of management of the data)

How to report data field B_02.02.0160 where the ICT service is not based or does not foresee data processing?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information

Template specific instructions – field B_02.02.0130 (Country of the governing law of the contractual arrangement)

How to report field B_02.02.0150 where the ICT service is not related to storage of data (B_02.02.0140 = 'No')?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information

Template specific instructions – field B_02.02.0130 (Country of the governing law of the contractual arrangement)

How to report field B_02.02.0130 where the ICT service is not supporting a critical or important function considering that according to the data model this data field is a primary key?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information

Template specific instructions - field B_01.02.0060 (LEI of the direct parent undertaking of the financial entity)

What should be reported in case the financial entity does not have a direct parent undertaking (for example, is the parent undertaking itself) or reports the register on an individual basis?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information

Template specific instructions – field B_01.02.0050 (Hierarchy of the financial entity within the group)

What does ‘where applicable’ mean in the title of data field B_02.01.0050?  What should be reported in this field in case the entity that is being reported in this template is not a financial entity (i.e., option 22, 23, or 24 was selected in field B_01.02.0040 for the entity type)?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/2956 - ITS on the register of information

4.0 Reporting Framework - COREP_OF C02 Template

Could you kindly clarify if, in the context of map C02 , the comparison should be made with line 0036 instead of line 0010, considering that the output floor is calculated at the consolidated level and not at the contract level?

  • 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)

DPM 400 - Modelisation of report C1000

we have a suspicion of schizophrenic modeling on the new C1000 report.  Indeed on this report when we look at the annotated templates it seems that all cells from column 0090 are sharing the same XBRL address as their corresponding cell for the same row from column 0100. Which means that from a technical point of view we will only be able to submit one “amount” per pair of cells C0090/C0100 for a dedicated row. For instance the Annotated templates stats that : {C_10.00, r0060, c 0090, s0000}=={C_10.00, r0060, c 0100, s0000} VariableID 3295841 VariableVID = 3295841    In the same time when we look at the ITS : We understand that may be possible that the transitional provisions do not apply  and so that or instance amount reported in cell 0020 _ 0090 can be equal to the amount in cell  0020 _ 0100 where the amount expected  for both cell is zero.  But we do expect from our understanding of the ITS that the transitional provision may apply and that the impact should be reported in various rows. In this case we will need to report different amounts on a specific row for those two columns, which seems unfeasible with the current setting.   Do you agree with our understanding?    

  • 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

C01.00 - CIU deduction from own funds

Where in the sheet C01.00 of the COREP, can we deduct CIUs under fallback approach (subject to 1250% RWA) from CET1 (as permitted by article 36.1.k.vi) since no dedicated caption is currently foreseen?

  • 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