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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

Identifying the customer of a collecting PSP

Does the fact that a collecting PSP (e.g. one providing the payment service acquiring of payment transactions to the payee) is involved in the flow of funds between the payer and the payee mean that the same PSP, if also providing merchant-facing payment initiation services, would have to assess the payer using PIS to be its customer in a different way than it would have to do if it were to provide PIS only (i.e. by way of deviation from what would otherwise apply according to Guideline 18.8 a of EBA/GL/2021/02))?

  • Legal act: Directive (EU) 2015/849 (AMLD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/02 - Guidelines on customer due diligence and the factors institutions should consider when assessing the ML /TF risk associated with individual business relationships and occasional transactions under Articles 17 and 18(4) of AMLD
  • ID: 2021_6243
  • Topic: Customer Due Diligence
  • Date of submission:
  • Published as final Q&A: 22/12/2023

Identifying the customer of a PISP

Is the assessment of who the customer is, from the perspective of a payment initiation service provider (PISP) with a merchant-facing business model (as referred to in Guideline 18.8 a) of EBA/GL/2021/02), affected by the frequency with which a single payer uses the PISP’s services?

  • Legal act: Directive (EU) 2015/849 (AMLD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/02 - Guidelines on customer due diligence and the factors institutions should consider when assessing the ML /TF risk associated with individual business relationships and occasional transactions under Articles 17 and 18(4) of AMLD
  • ID: 2021_6242
  • Topic: Customer Due Diligence
  • Date of submission:
  • Published as final Q&A: 22/12/2023

ITS ESG P3 - Annex II, Templates 10

1. Are general-purpose loans to pureplay companies in the scope of Template 10? 2. How sustainability linked loans with multiple sustainable performance targets be treated?

  • 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_6878
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 15/12/2023

ESG P3 - Template 3 - Indicators of potential climate change transition risk: Alignment metrics

In accordance with COMMISSION IMPLEMENTING REGULATION (EU) 2022/2453 in template 3, the institution shall disclose: 1/ Alignment metric(s) (column d) applied and the closest year of reference (column e) for the alignment metric(s) for each sector. Regarding the reference date, does it refer to the reporting date? Should it therefore have to change biannually depending on the publication of ESG Pillar 3? Otherwise, how often does it have to be updated?  2/ Institutions’ target for 3 years after the year of reference: If the reference year is different from the year of reporting (see question 1), for instance 2020 as reference date, then the target (column g) will be 2023 but as soon as the institution published the reporting for June 2024, this target won’t be relevant. Should the institution updated it and start again from 2023 as the reference date?

  • 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_6859
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 15/12/2023

Template 3 / Exposures to companies operating in several sectors

In Template 3, should corporate exposures corresponding to general-purpose financing lines be split across different sectors according to “the counterparties’ activity distribution, including by counterparties’ turnover by activity” (and therefore several different NACE codes), or should corporate exposures be fully allocated to one NACE code only corresponding to its main activity (as in template 1)? In the first option, how granular is the activity distribution expected to be reported, is there a minimum threshold of turnover to start reporting an activity? How is the information expected to be collected if not communicated by the corporates, can external data providers be used?

  • 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: 2023_6842
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 15/12/2023

Template 3 / Level of NACE codes to use

In Template 3, different levels of NACE code are indicated (level 1, 2, 3 or 4). What does this mean in practice, should banks report their full exposures falling under each level, or should exposures be reported in one category only? For example, for the fossil fuel sector a level-one NACE code is indicated (NACE code “6”) along with level 2 and 3 NACE codes (NACE code 61, 610…) – should exposures reported under code 610 also be included in exposures reported under 61 and 6? Please note that some NACE codes are overlapping (e.g. NACE code 8 is proposed for fossil fuel combustion and NACE code 89 is proposed for cement) – should exposures reported under 89 also be included in exposures reported under 8?

  • 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: 2023_6843
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 15/12/2023

Inclusion of repurchase transactions in financial assets and exposure value/risk-weighted assets (COREP C33).

What is the method to be followed concerning the inclusion of repurchase transactions in financial assets and exposure value/risk-weighted assets in COREP template C 33.00?

  • 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_6565
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 15/12/2023

Calculation of “Total exposure” and other concepts in G 01.00 (G-SII indicators and EBU items)

It is not clear from the instructions how to calculate the total exposure measure (and other measures) and their relation to the leverage ratio exposure measure reported in C 47.00.

  • 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_6355
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 15/12/2023

Application of the behavioural assumption of a 5-year cap for non-maturity deposits

Regarding paragraph 111 of the Guidelines on Interest Rate Risk in the Banking Book (EBA/GL/2022/14), and in relation to Article 98(5a) of the CRD, could you please confirm that the behavioural assumption of a 5-year cap on the average repricing of non-maturing deposits should not be understood as a modelling requirement neither for the Supervisory Outlier Tests (SOT) nor for the ongoing management of interest rate risk but as an alternative and additional measure of interest rate risk that complements the existing IRBB management framework?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2022/14 - Guidelines on interest rate risk arising from non-trading book activities
  • ID: 2023_6807
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as final Q&A: 03/11/2023

Prudent Valuation: Reporting of AVAs in C 32.03

How should the AVAs of model risk be reported in the template C 32.03. Can the Fair Value Adjustments linked to Model Risk, Model Risk UCS y Model Risk I&FC AVAs be included into the C 32.03?

  • 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_6817
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 13/10/2023

Central bank eligibility of cash

Should cash be reported as central bank eligible in F 32.01 (AE-ASS) if a bank can borrow securities against cash from the central bank?

  • 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_6749
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 13/10/2023

ESG P3 - Template 2 and 5 - Gross carrying amount for loans collateralized by RRE/CRE and multiple collaterals

Question 1: For loans collateralised by CRE and/or RRE, to be reported in template 2 & 5, does the regulation allow to have their gross carrying amount not matching the gross carrying amount of the same loans reported in FINREP? Question 2: Does Q&A 6517 apply for both template 2 and 5 or only for template 5?

  • 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_6714
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 13/10/2023

COREP v3.2 – C 33.00

Regulation (EU) 2022/1994 amending the implementing technical standards laid on in Implementing Regulation (EU) 2021/451 changes the direction of the 2nd parenthesis for the period intervals of rows 0170 to 0230, which generates a 'double counting', example below: r0170 [0 – 3M] r0180 [3M – 1Y] r0190 [1Y – 2Y] r0200 [2Y – 3Y] r0210 [3Y – 5Y] r0220 [5Y – 10Y] r0230 [10Y – more] The periods 3M, 1Y, 2Y, 3Y, 5Y and 10Y would be declared on 2 rows each time.

  • 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_6704
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 13/10/2023

Deferred Tax Liabilities (DTL) that are non-deductible from Deferred tax assets (DTA) as per accounting rule

Where do we book the temporary Deferred Tax Liabilities(DTL) differences that are non deductible from Deferred tax assets (DTA) as per accounting rule?

  • 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_6643
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 13/10/2023

Securitised derecognised assets

Template C 14.00 (SEC DETAILS), column 0210, requires reporting of information on securitised exposures including associated provisions. The memorandum item on the standardised calculation in C 14.01 (SEC DETAILS APPROACH), column 0448 also requires provisions on underlying asset as an input. What provisions should be used when the securitised exposures are also derecognised by the reporting entity from an accounting perspective?

  • 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_6548
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 13/10/2023

Transfers to PPE

We have a collateral obtained some years back that was classified as Commercial Immovable property. In the current year the Group decided to transfer this property to PPE and use it for its own branches.  In table 25.1 the below rows exist. Where can we put the transfer (therefore outflow) mentioned above? Outflow for which cash was collected Outflow with replacement by financial instrument Outflow due to negative changes in value

  • 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_6823
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 06/10/2023

Bucket definition (PD range) in the ITS on supervisory reporting

Does Q&A 6718 also modify the definition of the row 'PD Range'?

  • 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_6803
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 06/10/2023

Should collateral received via securities financing transaction that is subsequently sold short be reported as encumbered in F32.02? Follow-up question on 2014_946 related to short positions in Asset Encumbrance

As clarified in Q&A 946 “Selling collateral received (short sale) does not give rise to encumbrance”. Two scenarios are addressed under this Q&A and further clarity is sought on scenario one and the reporting of collateral received in template F 32.02 where such collateral is subsequently sold short. Is it the intended view that within F 32.02 where an institution receives collateral, against cash, and then uses that collateral received to cover a short position, that the received collateral should be reported as unencumbered in F 32.02, column 040?  If so, can you please provide supporting rationale that selling collateral received (short sale) does not give rise to encumbrance given that once the collateral is sold short, it is not available for re-use by the institution?

  • 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_6800
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 06/10/2023

Clarification of scope of population for Corporate Bonds

In accordance with the instructions for row 0060 of template C 34.08 in Annex II of Commission Implementing Regulation (EU) 2021/451, there is no specific definition of what the scope of corporate bonds should include. Could you, therefore, please confirm if this should include all bonds issued by Institutions and Corporate entities and if it would also include securitisation bonds issued by these entities as well or not or, alternatively, would only non-securitisation instruments issued by entities which would qualify for the corporates credit risk exposure class under Article 112(g) of the CRR be included? We would also request clarification on securitisation bonds, whether those issued by government agencies e.g., Fannie Mae should be reported in row 0050.

  • 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_6755
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 06/10/2023