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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

Applicability of SCA to electronically processed SEPA Direct Debits / Interpretation of EBA Q&A 2018_4359

Are mandates for direct debits which are set up without direct involvement of the payer’s PSP subject to SCA requirements?

  • 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: 2019_4664
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Currency conversion of the EUR thresholds contained in the RTS

May payment service providers (PSPs) and card schemes set rounded and easily understandable non-EUR currency equivalents for the EUR thresholds set out in the RTS?

  • 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: 2018_4040
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Testing eIDAS certificates before 14 September 2019

How can Third Party Providers (TPPs) and Account servicing payment service providers (ASPSPs) test their interfaces using PSD2 eIDAS-certificates during the testing period prior to September 2019 as it is only mandatory to use PSD2 eIDAS certificates from September 2019 onwards?

  • 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: 2018_4138
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Application of Transaction Risk Analysis (TRA) exemption – Real time risk analysis / monitoring

Is it acceptable if a payment service provider (PSP) looking to apply the TRA exemption makes a best effort using the information available to them to identify that none of the six individual factors mentioned in Article 18(2)(c) of the Commission Delegated Regulation 2018/389 are applicable, but does not have to actually identify non-applicability of all of these factors to be able to use the TRA 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: 2018_4127
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Exemption for secure corporate payment processes and protocols

May lodged and virtual cards benefit from the exemption for secure corporate payment processes and protocols under Article 17 RTS?

  • 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: 2018_4060
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Transaction Risk Analysis (TRA) exemption – Frequency of recalculation of fraud rate

Should the fraud rate, in accordance with Article 19 of the RTS, be recalculated every day using the trailing 90 days of data, or should it be recalculated once every 90 days (using the trailing 90 days of data)? If the fraud rate should be recalculated once every 90 days (using the trailing 90 days of data), can the calculation periods be aligned with calendar quarters? (e.g. the fraud rate for use during Q1 2020 (01-Jan-20 to 31-Mar-20) would be based on fraud data for Q4 2019 (01-Oct-19 to 31-Dec-19).

  • 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: 2018_4045
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Validation rule v1088_m

Validation rule v1088_m verifies that the amount entered in F01.01 row 280, column 010 (Property, Plant and Equipment in the Balance Sheet Statement) should be equal or larger than the amount entered in F13.02 row 020, column 010 (Property, Plant and Equipment obtained by taking possession during the period). This validation rule implies that collateral obtained in the form (nature) of Property, Plant and Equipment is classified in the Balance Sheet Statement as Property, Plant and Equipment. We believe in most cases the collateral obtained by taking possession will be classified as either held for sale (based on IFRS 5.6 and meeting the requirements from IFRS 5.7) or as “other assets” (based on meeting the conditions of IFRS 5.6, but not IFRS 5.7 (plan for immediate sale in present condition and sale being highly probable)) and thereby will be reported in either F01.01 row 370, column 010 or F01.01 row 360, column 010. We therefore question whether the current validation rule is appropriate.

  • 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: 2019_4464
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Securitisations reporting in C 09.04 for v 2.8

How should the securitisations under the new framework be reported in template C 09.04 in v 2.8?

  • 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: 2018_4408
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Reverse repos (Reverse Repurchase Agreements) in AE-Assets Encumbrance

RE 680/2014, Annex XVI, § 2.1.1.14 (b) deals with Repos / Matching (or Reverse) Repos in the AE-Assets Encumbrance reporting. Questions : 1)where must be reported in AE-ASS (F32.01) and by impact in AE-ADV1 (F36.01) the cash received by the reporting institution from its Reverse Repos ? because it should be registered among the Encumbered Assets whereas the (iv), taken over below in Background section doesn’t evoke the treatment for the carrying amount, contrary of Repos in the paragraph (iii). 2) the paragraph (iv) of the mentioned article indicates that the fair value of the collateral of reverse repurchase is reported including AE-SOU (F32.04), r050, c030 and 040 : is c030 provided for Reverse Repos and c040 for Reverse Repos regiven in Repos ?

  • 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: 2018_4372
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Validation rule v0853_m - Framework release 2.8

In tables F10.00 and F11.01 should the notional amount of derivatives be reported if the fair value is equal to zero?

  • 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: 2018_4355
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

FINREP Locom valued debt instruments: Reporting of "Accumulated negative value adjustments on LOCOM assets - credit risk induced"

Could it be that the following validation rules 5319_m until v5331_m are not correct for LOCOM valuated debt instruments. Should  "Accumulated negative value adjustments on LOCOM assets - credit risk induced"  be reported under accumalated impairment and not under "Accumulated negative changes in fair value due to credit risk on non-performing exposures"?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4336
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Finrep Solo GAAP: The following validation rules v5476_m until v5489_m are missing the column"Accumulated negative value adjustments on LOCOM assets - credit risk induced"

Dear Could it be that the the column "Accumulated negative value adjustments on LOCOM assets - credit risk induced" is missing in the validation rules from v5476_m until v5489_m?

  • 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: 2018_4335
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Difference in reporting requirements for C71 as per the EBA Annotated Reports and ITS Monitoring Metrics

There is some confusion in relation to two documents provided by the EBA on the ITS Supervisory Reporting website. In regards to the C 71.00 report, on the Annoted Report (see screenshot attached) it is shown clearly that the counterparty should not include "Central Banks" - but tat the same time in the ITS document also provided by the EBA (unable to attach more than one attachment for reference) for C 7.001, they mention clearly that "Central Banks" should be included in the Issuer/Counterparty Sector.

  • 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: 2018_4217
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Accumulated other comprehensive income in template C.01.00

Is the accumulated other comprehensive income in template C.01.00 the same amount than in row 090 in F.01.03? Is row 280 in F.01.03 also taken into account?

  • 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: 2018_4116
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Report gross or netted cash flows in the row 360 of C66 (maturity ladder) of non-forex and non-option-like derivatives under a valid netting agreement but without collateral agreement

« In the Annex XXIII (Maturity Ladder Instructions), for the row 360 ("1.5 Derivatives amount payables other than those reported in 1.4") , paragraph 2(b), it is stated that "flows related to other contracts than those referred to in point (a) shall be included by projecting the gross contractual flows of cash in the respective time buckets in lines 1.5 ‘derivatives cash- outflows’ and 2.4 ‘derivatives cash-inflows...’". Suppose that there is a group of derivatives (non-forex, non-option-like transactions) traded with the same counterparty under a valid bilateral netting agreement but without a collateral agreement in place, should netted cash flows per counterparty or gross cash flows be reported in row 360? If the netted cash flows should be reported in row 360, should the netted amount be calculated per day, or per time bucket defined for C66 report? For example, in C66, there is a time bucket 'Greater than 7 days up to 2 weeks', can we net an inflow of day 8 with an outflow of day 9 and then report only the net amount in row 360 (if negative) or row 670 (if positive)?”

  • 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: 2018_3943
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Low Credit Risk Template 4.4.1 and 4.3.1

Regarding the Column "of which: Instruments with low credit risk" detailed in the Template 4 series. Is there an expectation to have this populated by institutions which have not elected to adopted the practical expediency which IFRS 9 allows for the implementation of the new standard?

  • 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: 2017_3594
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Reporting of fees and levies in FINREP template F 02

How each the following expenses should be classified in FINREP template F 02, that is, should they be reported in row 350 (Other operating expenses), row 380 (Other administrative expenses), or under a different item? - contribution to the deposit guarantee scheme pursuant to national legislation implementing Article 10(3) of Directive 2014/49/EU of the European Parliament and of the Council - contribution to the Single Resolution Fund pursuant to Article 70(3) of Regulation (EU) No 806/2014 of the European Parliament and of the Council and Council Implementing Regulation (EU) 2015/81; or to a national resolution fund - a bank levy or a supervisory fee, such as the SSM Supervisory Fee (Regulation (EU) No 1163/2014 of the European Central Bank) or the “Dutch bank tax”.

  • 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: 2017_3574
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 07/06/2019

Certfication in relation to a Technical Service Provider (TSP)

When performing the role of a Technical Service Provider (TSP) is the TSP required to update the certificate received from the Third Party Payment Service Providers (TPP) (to demonstrate our involvement) to enable the Account Servicing Payment Service Provider (ASPSP) to authorise the certificate and provide the appropriate requested data back through to the TPP and establish the session? Is this same certificate required for every type of transaction request and must it be real time checked by the ASPSP and how does this impact our role as a TSP?Also, by introducing a TSP between a TPP and an ASPSP is the concept of private keys and the transport layer broken, due to the introduction of a TSP between the TPP and the ASPSP? Finally, are there limits to the number of roles involved in the chain in terms of the certification or do we just need to be able to demonstrate the link back to the point of origin for the certificate (the TPP)?

  • 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: 2018_4375
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 24/05/2019

Authentication code

Is it allowed to use the (authenticated) session that a user has (after logging in (with or without SCA)) as 1 of the authentication factor when performing SCA for a payment transaction?For example: A customer logs in with its username & password (knowledge) + SMS One Time Password (possession). Once in his online banking environment he looks at his statements. Within that same session (that ends after 5 minutes inactivity) he makes a payment.The question is if for authenticating the payment it is required to perform SCA again or if the authenticated session (based on the previous authentication) and a second SMS One Time Password (possession) that dynamically links the payment would suffice.

  • 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: 2018_4141
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 24/05/2019

Information to be provided / made available by ASPSP to payment initiation service provider (PISP)

In the context of PIS:(a) shall the ASPSP, upon initiation of the payment session, provide or make available to the PISP the IBANs/account numbers for all payment accounts from which the user can transfer funds, and the associated currencies; and(b) shall the ASPSP, in each communication session, provide or make available to the PISP/AISP the name of the payment service user that is accessing the accounts.

  • 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: 2018_4188
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 10/05/2019