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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

Exemption from strong customer authentication

Do the revisions to Art.10 set out in Commission Delegated Regulation (EU) 2022/2360 of 3 August 2022 amending the regulatory technical standards laid down in Delegated Regulation (EU) 2018/389 as regards the 90-day exemption for account access mean that a payment service user or account information service provider is now limited to accessing only the account balance OR the transaction details for the last 90 days when availing of the revised exemption?

  • 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: 2023_6820
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 29/09/2023

App to app redirection with biometrics for PIS

Are ASPSPs required to offer redirected authentication with biometrics to users accessing their payment accounts through an AISP or initiating a payment through a PISP, if they offer redirected authentication with biometrics to users accessing accounts or initiating payments directly via the ASPSP?

  • 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: 2023_6767
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 29/09/2023

Service Downtime

The question refers to the case that an incident with a duration of two hours that disrupts transaction processing occurs around the daily cut off time of same-day transactions processing. Thus, the incident may be of a short duration, but as a result, transactions are booked one day later. Considering this example, what service downtime should the payment service provider (PSP) indicate in the PSD2 notification? Just the net time of the failure or the total time any payment service users are affected by delayed transactions, i.e. one day?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/03 - Guidelines on major incident reporting under PSD2 - repealing EBA/GL/2017/10
  • ID: 2023_6744
  • Topic: Major incidents reporting
  • Date of submission:
  • Published as final Q&A: 29/09/2023

Period to be covered by statistics pursuant to Article 32(4) of Commission Delegated Regulation (EU) 2018/389

Which period should the statistics to be published by ASPSPs under Article 32(4) of Commission Delegated Regulation (EU) 2018/389 cover in total?

  • 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: 2023_6687
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 29/09/2023

Evidences / Records to be stored by account servicing payment service providers (ASPSP) for payment initiation service (PIS) and account information service (AIS) requests

Shall ASPSP keep record of PIS requests received through a PISP and evidences on the authenticity and execution of these payment transactions when SCA is managed by ASPSP ?  Shall ASPSP keep record of the consent of the PSU and also of the AIS requests received through an AISP ? For both evidences is there any specific retention period ?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6526
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 29/09/2023

Reading of the term "means of payment"

What are the 'means of payment' in the LNE Guidelines (guidelines 1.6 and 1.7)? Does the term refer to the technological level of a physical device or a digital carrier, which may accommodate several payment instruments, such as plastic card (chip or magnetic stripe), a mobile phone, a wallet, an app, a wearable, a tablet, a PC or even a specific storage location on an external server? Please provide examples of 'other means of payment' that are relevant in practice from the EBA's perspective. How is the definition of payment instrument according to Article 4(14) PSD2 to be read in the context of the LNE Guidelines? Is the interpretation of the adjective “card-based” (in combination with means of payment) in line with the same adjective in combination with payment instruments according to Article 2(20) of Regulation (EU) 2015/751 (“IFR”)?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2022/02 - Guidelines on the limited network exclusion
  • ID: 2022_6481
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 29/09/2023

C43.00 (LR4) – Reporting of RWA for positions in CIUs

What value for RWA shall institutions report for positions in CIU considering that the look-through approach shall not be used for Leverage Ratio purposes?

  • 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: 2023_6692
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 22/09/2023

Permission to reduce own funds or eligible liabilities and deduction rules in the context of a liability management exercise (exchange offer, tender offer or issuance of a replacement instrument concurrent with a tender offer on the existing instrument)

Should deductions from own funds and eligible liabilities with regards to a permission to reduce own funds or eligible liabilities in accordance with Article 77 of Regulation (EU) No 575/2013 (CRR) in the context of a liability management exercise (exchange offer, tender offer or issuance of a replacement instrument concurrent with a tender offer on the existing instrument), rather than upon the exercise of a call option,  be made right after the permission from the competent authority / resolution authority is granted or could it be later at the time of the institution’s public announcement of the liability management exercise in accordance with Article 28(2) of the RTS on Own Funds? In that context, how should the concept of ‘sufficient certainty’ of Article 28(2) RTS be applied?

  • 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: 2023_6791
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 15/09/2023

IFR reporting

What would be an example of how firms should read Article 20(1) IFR for reporting purposes in template I 06.07 and I 06.08 of annex I to Regulation (EU) 2021/2284?  

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/2284 - ITS on Reporting
  • ID: 2022_6384
  • Topic: Supervisory Reporting (IFR)
  • Date of submission:
  • Published as final Q&A: 25/08/2023

ESG P3 - Templates 6, 7 and 8 - Scope of application as of 31.12.2023 and institutions’ exemption from EU taxonomy reporting until mandatory CSRD reporting as of 31.12.2024

Is the institution obliged to disclose Pillar III ESG templates 6, 7 and 8 as of 31.12.2023 despite its current exemption from EU taxonomy reporting until mandatory CSRD reporting as of 31.12.2024?

  • 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: 2023_6695
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 25/08/2023

ESG P3 - Reg 2453/22 - Scope of application

What is the scope of application of Regulation (EU) 2022/2453? 

  • 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: 2023_6708
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 25/08/2023

ESG P3 - Template 7 Decision tree KPI GAR for Households

In which row/group of rows from template 7 should be disclosed Households not included in the of which populated on the template (loans collateralised by residential immovable property, building renovation loans, motor vehicle loans)?

  • 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: 2023_6780
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 25/08/2023

The risk-weighted exposure amount of the CIU’s exposures in mandate based approach

Could the institution use the information from the CIU management company about the notional amount of derivative positions of CIU to assess the value of those derivatives in calculating risk-weighted exposure amount of CIU when using the mandate based approach in accordance with Article 132a(2) CRR? In particular, is the institution allowed to use the information from the CIU management company, that CIU doesn’t have derivatives in their portfolio and assess the value of those derivatives as zero in calculating risk-weighted exposure amount of CIU when using the mandate based approach in accordance with Article 132a(2) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6670
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 04/08/2023

Reporting of deposits subject to a notice period for C 69.00 and C 70.00 purpose

Following Q&A Q&A 4574 (C 70.00) and Q&A 5794, some clarifications are needed concerning the amount to be reported in the C 69.00 for a deposit subject to a notice period. In our proposed answer, we use the terms of the Q&As and we specify the amounts we assume are expected for the 2 reports C 69.00 and C 70.00. Please, could you confirm if our interpretations are correct.

  • 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: 2022_6663
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 28/07/2023

Calculation of the amount reported for guarantees received on report F09.02

Should the amount of financial guarantees reported in F 09.02 be calculated considering (other) collateral?

  • 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: 2023_6773
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 30/06/2023

Pillar 3 disclosures prepared from FINREP reporting

In which column in the table EU CR1 should be included purchased or originated credit-impaired financial assets?      

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR
  • ID: 2022_6579
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 30/06/2023

MREL – reporting of the impact of general prior permissions

Reporting entities should deduct the pre-determined amount of a general prior permission for eligible liabilities instruments from the amount of their eligible liabilities from the moment the authorisation is granted. Against this background, how should this deduction obligation be reflected by the reporting entities in the reporting templates to be submitted in accordance with Regulation (EU) 2021/763?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/763 – ITS with regard to the supervisory reporting and public disclosure of MREL
  • ID: 2022_6576
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 30/06/2023

Disclosure of Template CR2 where NPE threshold of =>5% has not been breached

As per the mapping tool provided by the EBA, the Pillar 3 Disclosure Templates - 'CR2' is mapped to FinRep Template 24.1. This particular FinRep template is only reportable where the ratio of gross carrying amount of non-performing loans and advances divided by the total gross carrying amount of loans and advances subject to the definition of non-performing according to Article 47a of the CRR is equal to or higher than 5%. One therefore would assume that the 'CR2' Pillar 3 Disclosure template is not required unless the threshold is breached. However, Article 9 within the Pillar 3 ITS appears to imply that that 'CR2' is required regardless of the threshold by large institutions, as called out specifically as part of Point 1(e) of Article 9, This is also apparent in Point 3 of Article 9, where 'CR2' is not mentioned within the paragraph concerned as being a template that is determined for disclosure depending on the threshold. Can the EBA confirm the position on the same, given the requirement from the reporting perspective.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR
  • ID: 2022_6524
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 30/06/2023