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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

Counterparties referred to in Article 428h (1) (c) CRR

Does Article 428h (1) (c) of regulation 2019/876, amending Regulation No 575/2013, imply that the counterparty necessarily must be a bank? More specifically, would this condition also be met if the counterparty is a private limited liabilities company, which according to Regulation 575/2013 is not required to apply the NSFR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5253
  • Topic: Liquidity risk
  • Date of submission:
  • Published as final Q&A: 24/09/2021

Requirements towards SCA if association is done based on phone call

Does the requirement to apply Strong customer authentication (SCA) under Article 24 paragraph 2 b of Regulation (EU) 2018/389 - RTS on strong customer authentication and secure communication apply when customer is served using telephone call? Or is the only possibility to associate authentication credentials with the customer not having active credentials at hand, only possible having customer present?

  • 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_5650
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 24/09/2021

Delegation of 2-Factor Authentication (2FA) to PISP, AISP or other third party

Where a Payment Service Provider (PSP) is providing financial services via a third party application - either through a Payment Initiation Services Provider (PISP), Account Information Service Provider (AISP) or by providing embedded financial products or banking as a service solutions (i.e. financial services via an Application Programming Interface (API)) - is it permitted for the PSP to delegate the application of 2-Factor Authentication (2FA) to the third party?

  • 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_5643
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 24/09/2021

Association with the payment service user by means of a remote channel

Is it sufficient to use a company level knowledge element, in combination with a peronal posession element to associate a user of a business application with personalised security credentials such as authentication software or a knowledge element?

  • 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_5626
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 24/09/2021

Clarification on level of protection required for the processing of the IBAN outside the inter-PSP environment

Can the IBAN of the payer or payee be handled in cleartext outside the inter Payment Service Provider (PSP) environment? For instance could a payer’s IBAN be contained in cleartext in a payer-presented QR-code provided by the payer’s device to the merchant’s point of interaction for the initiation of an (instant) credit transfer? Or could a merchant’s IBAN be contained in cleartext in a merchant-presented QR-code at the merchant’s point of interaction to be read by the payer’s device for the initiation of an (instant) credit transfer?

  • 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_5477
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 24/09/2021

Clarification on the qualification and protection requirements of a CustomerID when included in a payer-presented QR-code for the initiation of (instant) credit transfers at the point of interaction (POI)

Is the CustomerID (i.e. ID issued by an Account Servicing Payment Service Providers (ASPSP) to its Payment Services User (PSU) for accessing the on-line banking system and usually required by PSD2 Application Programming Interfaces (APIs) to identify the PSU) to be qualified as “personalised security credentials of the PSU” within the meaning and for the purposes of Article 66 (3) b), PSD2, and Article 35 (5), RTS, and therefore be treated as “sensitive payment data” within the definition of Article 4 (32), PSD2? Accordingly, can said CustomerID be included in cleartext in the payer-presented QR-code for the initiation of (instant) credit transfers at the point of interaction (e.g. POS, vending machine) without any protection during the QR-code life-cycle, including the generation of the QR-code, storage of the QR-code on the payer’s device, transmission from the payer device to the payee’s point of interaction and in the payee’s (e.g. merchant) point of interaction?

  • 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_5476
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 24/09/2021

Intermediaries and Merchant-ID

In the hotel industry, given that when a customer reserves a room, a payment is often not taken at this time, should an entity (intermediary, online travel agent or brand/hotel group) that collects payment details from a customer also facilitate strong customer authentication (SCA), regardless of when or by whom the actual payment transaction may be processed? If yes, should the customer be explicitly informed of the entities involved in order for their consent to be valid?

  • 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_4796
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 24/09/2021

Validity of SCA

If  Strong customer suthentication (SCA) is required at the time of booking which is more than 90 days before the guest’s arrival, will hotels be able to process the payment at location with an expired authentication token? If not, can an SCA be renewed and who would be responsible for doing so?

  • 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_4795
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 24/09/2021

Application of national decisions pursuant to Article 124(2) CRR

Is it mandatory pursuant to Article 124(5) CRR for an institution in another member state to apply national decisions, which purport to be released pursuant to Article 124(2) CRR, but are not published on the EBA website under Rules and Guidance?Furthermore, if such national decisions are not published under Rules and Guidance, but e.g. under Options and national discretions only, is it mandatory that institutions from other member states apply such decision pursuant to Article 124(5) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2019_4600
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 17/09/2021

Inclusion of Held for sale in Other adjustments in template F 12.01

Where shall the changes in allowances for financial assets, which have been reclassified as held for sale prior to a disposal, be reported in FINREP template F 12.01?

  • 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: 2021_5840
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 10/09/2021

Inclusion of central bank exposures in template C 33.00

Shall exposures to central banks be included in the COREP template C 33.00?

  • 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: 2021_5825
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 10/09/2021

Allocation of non-performing interdependent assets for NSFR purposes

How should non-performing interdependent assets be allocated in the NSFR template for required stable funding?

  • 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: 2021_5822
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 10/09/2021

How to report liabilities with notice period in C69.00 and C70.00

How can evergreen repos be reported in the C69.00 template? How can deposits with notice period > 1 day be reported in the C69.00 and C70.00 template?

  • 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_5794
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 10/09/2021

Disclosures of Staff expenses Management body in its supervisory function in FINREP Template 44.4

In the countries where we operate supervisory board and management board are two separate bodies. The supervisory board also has members which are not employed by the reporting entity but still receive remuneration for their function. We would like to understand, if this remuneration has to be presented in template 44.4 column 0040 and if yes, should those external remuneration be presented consequently in staff expenses (FINREP Template 2 - Statement of profit or loss in a r370, c010 )?

  • 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: 2021_5793
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 10/09/2021

Public development credit institution - reporting in Rows 0262, 0263, 0264 of C 47

The instructions for rows 0262, 0263, 0264 of the C 47 template (DPM 3.0) refer to same Articles 429a(1)(d), 429a(2) and 429a(3) of the CRR. Further, the guidelines about public development credit institutions referred to in CRR article 429a(2) are the same, and instructions for the rows 0262, 0263 and 0264 of C 47 are similar. How to distinguish the exposures in these 3 rows?

  • 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: 2021_5743
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 10/09/2021

Validation rule v7378 - securitization templates C 13.01 and C 14.01

Should validation rule v7378 be triggered in case you have 1 entity which leads to a significant risk transfer (SRT) and 1 entity that is not leading to a SRT?

  • 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: 2021_5736
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 10/09/2021

Treatment for repo / reverse repo of liquid asset transacted outside the segregated pool for institutions operating under Article 8.3.a

1. For a credit institution reporting under article 8.3.a, should liquid asset collateral in repo / reverse repo transactions away from the segregated pool be reported in “of which collateral extended / received meets operational requirements” rows of templates C73 (e.g. row 1035) and C74 (e.g. row 311)? 2. For a credit institution reporting under article 8.3.a, should cash outflow from repo transactions away from the segregated pool be reported in row 070 (“Secured cash 30 day outflows”) but associated liquid asset collateral not be reported in row 060 (“L1 excl. EHQCB collateral 30 day inflows”) of template C76?

  • 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_5692
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 10/09/2021

Validation rules between template F 18.01 and F 24.01

We have three groups of rules affected: A. There are these validations in template F 18.01 : Template ID columns Formula F 18.01 v7866_m (0010) {r0050} >= {r0070} + {r0080} F 18.01 v7867_m (0010) {r0050} >= {r0090} F 18.01 v7868_m (0010) {r0100} >= {r0110} F 18.01 v7869_m (0010) {r0100} >= {r0120} F 18.01 v8114_m (0010) {r0050} >= {r0060} F 18.01 v8115_m (0010) {r0060} >= {r0070} F 18.01 v8116_m (0020) {r0050} <= {r0060} F 18.01 v8117_m (0020) {r0060} <= {r0070} B. There are validations between these templates: ID Formula v8509_i {F 18.01, r0060, c0010}=={F 24.01, r0020, c0050} v8510_i {F 18.01, r0060, c0020}=={F 24.01, r0120, c0050} v8511_i {F 18.01, r0070, c0010}=={F 24.01, r0020, c0060} v8512_i {F 18.01, r0070, c0020}=={F 24.01, r0120, c0060} v8513_i {F 18.01, r0080, c0010}=={F 24.01, r0020, c0070} v8514_i {F 18.01, r0080, c0020}=={F 24.01, r0120, c0070} v8517_i {F 18.01, r0110, c0010}=={F 24.01, r0020, c0030} v8518_i {F 18.01, r0110, c0020}=={F 24.01, r0120, c0030} C. And this within template F 24.01: ID Template Formula v8051_m F 24.01 {r0320} = {r0010} + {r0020} + {r0120} Knowing that we have to comply with rule group A, rules B and C cannot be complied simultaneously. What set of rules should we follow, B or C?

  • 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: 2020_5613
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 10/09/2021

Treatment of securities received in reverse repo and sold (short position) in F32.04 and F08.01

Our question is about the link between F32.04 and F08.01 for reverse repo, notably if the securities received is sold (short position). Our position is: - Securities in reverse repo don’t have to be reported in F 8.1 (only repo have to be reported) but should be mentioned in cell 160_030 in F32.04, - Securities received and sold have to be reported in F 8.1, cell 040_010, - The sum of row 10 to 110 (column 010) of F32.04 have to be matched with liabilities reported in F08.01. Do you agree with this treatment? If not, could you precise your recommendations?

  • 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: 2015_2202
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 10/09/2021

Specialised Lending Supervisory Slotting Method and CRM Substitution Approach

1) Can the CRM substitution method be used for specialised lending exposures when the supervisory slotting method is applied under the CRR?2) If this answer is yes, can we request that the relevant cells in template C8.01a (i.e. columns 70 and 80) are opened for rows 90-150 to allow banks to report this information correctly?

  • 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: 2014_1604
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 10/09/2021