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

ITS ESG P3 - Non-financial risks and value chain

1. Should entities report their own non-financial risks arising from its own operations, or only the non-financial risks related to the operations of its counterparts and customers? 2. If “counterparts” includes the latter then; what is the definition of a “counterpart” ? Does it include the third party value chain e.g. suppliers and outsourcing agreements?

  • 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: 2022_6544
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 17/02/2023

ITS ESG P3 - Annex II, Templates 1, 2, 4, 5

With regard to exposures for template 1 and 5, should loans, debt and equity instruments to financial corporations be excluded from reporting and, if so, on what basis? Should exposures to financial corporations be included? With regard to template 1 Column (b): Should exposures to counterparties that are excluded from the EU Paris-aligned Benchmarks be reported only for public companies?     Column (c): Please confirm that the ‘of which environmentally sustainable (CCM)’ column is only required for disclosure as of end 2023? Column (j): For scope 3 emissions of counterparties: Should the PCAF and EU benchmarking sector-specific “Scope 3 phased in approach” be adopted, where only scope 3 emissions for coal, oil gas etc. be reported (from end 2020 onwards), etc.” (see here below from the EU Benchmarking directive)? With regard to template 2, columns (h) to (n), which database should be used for buildings with EPC Labels?  With regard to template 4 Point 21: would it be acceptable for reporting institutions to use various data providers?  Is “carbon intensity” meant to include scope 3 emissions or solely scope 1 and 2? If scope 3 emissions are included, should only reported data be included or include estimated data? Should disclosures refer only to CO2 or to all greenhouse gases in CO2 equivalent?​ Is this a footprint (i.e., absolute emission) or intensity (e.g., relative based on turnover, production or the like) metric? If intensity, what is the denominator? At what cadence should the list of companies be updated? Are the ‘Top 20 Carbon-Intensive Firms’ with respect to a world-wide comparison? Column (a): Does ‘Gross carrying amount (aggregate)’ require banks to report the total gross carrying amount of their banking book and part (b) ‘Gross carrying amount towards the counterparties compared to total gross carrying amount (aggregate)’ require the reporting of the ratio of the carrying amount towards the top 20 emitting companies to the total gross carrying amount? Column (c): is the ‘of which environmentally sustainable (CCM)’ column only required for disclosure as of end 2023? Column (d): is the ‘weighted average maturity’ only required for the carrying amount for counterparties among the top 20 carbon emitting companies? With regard to template 5  General: What point in time and what climate change scenario should the exposure be assessed?  Point 24: ​'Should reporting institutions report separately for different geographic regions, i.e., a separate excel sheet per geographic region and, if yes, what would be the appropriate level of detail for such regions?​ Does the 'breakdown by geography of location' imply that the exposure should be assessed at the location level and overall aggregated exposure across all regions be reported?​ Point 25: are third party data providers’ hazard models for the identification of geographies prone to climate hazards?

  • 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: 2022_6600
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 17/02/2023

Cash pool assets in C 47.00

As per ITS of C47, Cash pool assets are to be reported in C47 Rows 0193 to 0198. [1] As net amount of cash pool asset for the group entity are likely to reported in Row 0190, of C47 as other assets. Is it not double counted to the extent of amount reported in Row0190 with regard cash pool assets? [2] As there is validation (v4456) between C47 Rows 0010 to 0290 = C43 total assets, where are these cash pool assets as reported in C47 are to be reported in C43? [3] Whether Cash pool assets as reported in C47 are also to be reported including positive and negative amounts. [4] Is the scope of prudential netting mentioned under article 429b, applicable only for Leverage ratio or does this prudential netting has some thing to do with prudential report applications like COREP?   

  • 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
  • ID: 2021_6094
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 17/02/2023

Securities lent under sale accounting

As per ITS, in line with article 429e (6) of CRR2, The value of securities lent in a repurchase transaction that are derecognised due to a sales accounting transaction under the applicable accounting framework are to be reported  Row 230 of C47. [1] For such repurchase transactions under sale accounting, cash received part is to be allocated in Row 0190 of C47? So also in C43 and C40 the same rule applies? In 47, Row 010, securities under sale accounting are not to be reported as they are expected in Row 230 of C47. [2] The same rules apply to C48 with regard to columns of rows in C47 0010 to 0050, which are to be reported in C48.02 in line with ITS. The validation rule v10094_m expects Row0010 |Col0020 >= Row0010|Col0030 Is this possible as only reverse repo leg and add-on are expected in Col0020 are to be higher or equal to the value of  securities lent under sale accounting are to be reported in Col0030?  [3] As per EBA guidelines, where the institution adopts sale accounting of repo, they should reverse such transactions and report in COREP reports including Leverage ratio. It means, except for the change for securities under sale accounting are to reported in Row 230, while the institution which does not adopt sale accounting are to report own securities under Row0190. Except for this change, add-on and other calculations are same. Please confirm. 

  • 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
  • ID: 2021_6093
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 17/02/2023

ITS ESG P3 - EU Taxonomy Consolidation scope

Which consolidation scope is appropriate for the EU taxonomy disclosures in P3 ESG, given the conflicting regulatory guidance from the EU taxonomy and the NFRD and given that the EU taxonomy is disclosed in the annual report and therefore, the consolidation scope we would prefer to apply is the IFRS consolidation scope rather than the prudential scope?

  • 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: 2022_6601
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 17/02/2023

Definition of "accounting value" for the purpose of template C 80.00

Should the assets, except for the derivatives contracts,  be presented in template C 80 from Regulation (EU) 451/2021 as gross accounting value (not affected by  general and specific allowances) or as net (affected by  general and specific allowances)? 

  • 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
  • ID: 2021_6026
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 17/02/2023

Application of NPE prudential backstop in connection with the new COREP templates

The application of the requirements of Articles 47a, 47b and 47c of the CRR is connected with a new COREP reporting requirement for NPE loss coverage envisaged in templates C 35.01, C35.02 and C 35.03. When filling that new COREP reporting templates a the following question has appeared: do all three or any of COREP 35 reporting templates include NPE for which 100% of impairments was already made, that have accounting exposure value of 0 and 100% of specific credit adjustments?

  • 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
  • ID: 2021_5859
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 17/02/2023

ITS ESG P3 - Template 5 - Column B carrying amount

In ESG disclosure template 5: Should the amounts disclosed in column b be equal to the carrying amounts disclosed in column a in template 1, or; Should the amounts in column b only include exposures exposed to physical risk according to the definition in the new Article 18a § 1c?

  • 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: 2022_6615
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 17/02/2023

ITS ESG P3 - Template 5 - Physical risk models - Template 1 - Power generation thresholds

Question 1: Regarding power generation thresholds as outlined in the EU article 12.1(g) of the EU Paris-aligned Benchmarks Regulation referenced in Template 1: “companies that derive 50 % or more of their revenues from electricity generation with a GHG intensity of more than 100 g CO2 e/kWh.” (a) Should we look at % revenue by separate sources of fuel or %revenue for the combined fossil fuel power generation of this company? (B) This can be interpreted as a dual factor (revenue from power generation and power generation carbon intensity). What happens if one of the factors is fulfilled, i.e. more than 50% of revenue from power generation, but not the other, i.e. less than 100 gCO2e/kWh. Question 2: Regarding Template 5, do banks need to include exposures based in non-EU geographies? There is no explicit guidance on Template 5. Question 3: Regarding Template 5, we would propose a physical risk assessment for the REMIND NDC climate change scenario (roughly 3 degree global warming in 2100) for the year 2050 (and also with data for “today” ). Is this in line with what the EBA expects? Question 4: Regarding Template 5, which option below is the correct information to fill out for column (j) “of which exposures sensitive to impact both from chronic and acute climate change events”? Question 5: Under which circumstances do banks outside the EU (e.g., Switzerland, UK or US Banks) need to report under EBA Pillar 3? Will the EBA provide a list also for these non-EU based banks falling under EBA Pillar 3?

  • 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: 2022_6623
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 17/02/2023

Deductions

The capital items and instruments in the NSFR shall be reported prior deductions. The deductions should be reported as other assets with a RSF of a 100% (Article 429o, point (a), CRR). Should the off-balance deductions be reported on this row as they need an associated RSF, or they shouldn’t be reported at all?

  • 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
  • ID: 2021_5772
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 17/02/2023

ITS ESG P3 - Template 2 - Column A & Totals in row 5 and 10

Two questions with regard to Template 2:  Banking book - Climate change transition risk: Loans collateralised by immovable property - Energy efficiency of the collateral: 1) Should the columns h-p sum up with b-g and simultaneously with the column a? 2)  In which lines to report a situation in which the bank estimates the energy efficiency of collateral a housing mortgage? Should rows 5 and 10 be a sum of rows 2-4 and 7-9 respectively?

  • 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: 2022_6625
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 17/02/2023

Assets which are not immediately available for monetisation in C 66.01

In relation to the reporting of the C 66.01 maturity ladder template, what is the treatment of assets which are generally eligible as counterbalancing capacity but which, from the perspective of the reporting institutions, are not immediately available to cover potential contractual funding gaps?

  • 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
  • ID: 2020_5158
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 17/02/2023

ITS ESG P3 - Template 1 - Scope 3 & Sector average emissions intensity

Three questions with regard to Template 1: Banking book- Climate Change transition risk: Credit quality of exposures by sector, emissions and residual maturity: 1) column I: How to understand this instruction relating to Scope 3: The estimation of scope 3 emissions per sector shall be done in a proportionate way: e.g. by taking the institution’s exposures (loans and advances, debt securities and equity holdings) towards the counterparty compared to the total liabilities (accounting liabilities and shareholders’ equity) of the counterparty? 2) column I: How will the bank use the estimates of "sector avarage emissions intensity" in template 1? 3) What type of data should the bank disclose in scope 1 and 2? In the template 1 table, there is a separate column for Scope 1, 2, and 3, and separate for Scope 3 itself. Scope 1 and 2 are the consumption of the organization, they do not concern financing – what exactly is the bank to report there?  Full Scope 1 and 2 of  clients or in some proportion?

  • 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: 2022_6626
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 17/02/2023

Calculation of goodwill included in the valuation of significant investments in insurance undertakings

A. For the purposes of a deduction under Article 36(1)(b) CRR, should the goodwill (Article 4(1) no. 113 and 115 CRR)  included in the valuation of significant investment                      be calculated at the acquisition date by separating any excess of the acquisition cost over the banking group’s share of the net fair value of the identifiable assets and liabilities of the insurance undertaking or be the amount disclosed as goodwill in the IFRS/NGAAP consolidated balance sheet of the parent institution (or parent financial holding company or parent mixed financial holding company, as applicable) in proportion of the participation recorded for prudential purposes (i.e. in case of participation of 100%, the full goodwill should be deducted, including also goodwill generated at the level of the insurance undertaking)?    B. Would the application of Article 49(1) CRR provide the possibility to risk weight rather than deduct the goodwill included in the valuation of significant investment in insurance undertakings?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_6211
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 10/02/2023

Definition of exposures arising from mortgage lending

Which value of the exposure is the amount that can be reduced, when referring to "the pledged amount of the market value or mortgage lending value of the property concerned, but by not more than 50 % of the market value or 60 % of the mortgage lending value”?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2021_5756
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 10/02/2023

Clarification of the relationship between EBA's Guidelines on outsourcing arrangements and Section 4 of the Directive (EU) 2015/849 - AML

Does the term of outsourcing (paragraphs 12 and 26) of EBA GL/2019/02 include performing of customer due diligence by third parties under Section 4 of the AMLD4, i.e. whether or not the application of GL/2019/02 to Performance by third parties would be in violation of the AMLD4?

  • Legal act: Directive (EU) 2015/849 (AMLD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5100
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 10/02/2023

SCA for token replacement

Is SCA required for the replacement of a tokenized card happening in the background without any ‘action by the payer’ under Article 97(1)(c) PSD2 in the following cases: Expiry of the token and update of the token Replacement of the card, and the new card has a different BIN/Account Range (e.g., for product graduation, such as standard to gold, or simple BIN management) and/or different functionalities Technical and/or configuration changes to the issuer’s BIN configuration (such as migrating from 6 to 8 digit BINs) In all these cases, the existing tokenized credentials have been initially associated with SCA to the user under Article 24(2)(b) RTS, and this is solely a technical replacement of the token. credentials have been initially associated with SCA to the user under Article 24(2)(b) RTS, and this is solely a technical replacement of the token.

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2022_6464
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 31/01/2023

SCA applicability / Application of SCA at tokenisation stage

Does the authentication to unlock the mobile device count as one of the elements of strong customer authentication when a payment service user is tokenising a card on an e-wallet solution such as Apple Pay?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2021_6145
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 31/01/2023

Application of SCA to issuing a payment instrument and tokenisation

Is strong customer authentication (SCA) required when a Payment Service Provider (PSP) issues a payment instrument or creates a token?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication
  • ID: 2020_5622
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 31/01/2023