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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

Ability of static card data to be considered a possession factor?

Can static card data (Card number PAN + cardholder name +Exp. Date + static CVV2/CVC2) be considered a as a possession factor, and if so: is it strong enough to be a valid factor in a 2-factor Strong customer authentication (SCA)?

  • 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_4235
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 15/01/2021

SMS OTP and credit card as a two authentication factor

Can we consider Credit card and One Time Password (OTP) SMS as a two authentication factor ? 

  • 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_4135
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 15/01/2021

Unlikeliness to pay (UTP) - exit from NP status

Can a customer exit non-performing status immediately (provided of course no other UTP criteria are applicable), or does a period of 12 months need always to pass before the customer can exit?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2018/06 - Guidelines on management of non-performing and forborne exposures
  • ID: 2019_4867
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 15/01/2021

Article 395 CRR – Shadow entities large exposure limits

If a bank invests through a vehicle, incorporated under the applicable Securitisation Law, with separate compartments per investor and where the paid out of each Note is segregated per portfolio of loans, may each Note be deemed a separate shadow entity?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2015/20 - Guidelines on limits on exposures to shadow banking entities which carry out banking activities outside a regulated framework under Article 395(2) of CRR
  • ID: 2019_4501
  • Topic: Large exposures
  • Date of submission:
  • Published as final Q&A: 15/01/2021

Criteria for rating transfer

Can “clear policies” referred to in paragraph 62 – such as recognising the relationship between a subsidiary and its consolidating parent or recognising any other form of control as defined in Article 4(1)(37) of Regulation (EU) No 575/2013 – which lack the features of a material contractual support – be considered as “appropriate guarantee", thereby supporting  the rating transfer?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2017/16 - Guidelines on PD estimation, LGD estimation and the treatment of defaulted exposures
  • ID: 2019_4745
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/12/2020

Collateral swap in case of Domestic Central Bank Counterparty

With the Amended Delegated Act 2018/1620, what are the run off rates and where collateral swaps with central bank counterparties must be reported ?

  • 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_5190
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 04/12/2020

Credit for consumption

How should "Credit for consumption" be interpreted for reporting in FINREP templates 5.1, 7.1, 18, 19 and 20.4? There appears to be two plausible and defendable means of determining the intended scope.

  • 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_5167
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/12/2020

Reporting of the Undrawn limits of credit cards and overdrafts in F09.01.1 Off-balance sheet exposures: Loan commitments, financial guarantees and other commitments given.

Where to report the Undrawn limits of credit cards and overdrafts? Should the Undrawn limits of credit cards and overdrafts be shown in F 09.01.1 row 10 (Loan commitments given) or in row 170 (Other commitments given)?

  • 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_5159
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 04/12/2020

Reporting of (committed) credit and liquidity facilities in the C 66.01 maturity ladder template

Are the committed facilities to be reported in row 1090 (under ID 4.1) of the C 66.01 maturity ladder template strictly limited to the committed credit and liquidity facilities referred to in Article 31 of amended Delegated Regulation (EU) 2015/61 or should institutions consider a broader scope of such facilities?

  • 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_5157
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 04/12/2020

Treatment of impediments to the availability of assets and cash inflows in the C 66.00 maturity ladder template

How should potential impediments to the availability of assets and cash inflows be considered in the C 66.00 maturity ladder template?

  • 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_5156
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 04/12/2020

Netting of cash flows in the C 66.00 maturity ladder template

Can institutions report cash flows on a net basis in the C 66.00 maturity ladder template, in particular where such netting of cash flows is explicitly allowed for the purpose of the calculation of the Liquidity Coverage Ratio (LCR)?

  • 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_5155
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 04/12/2020

Reporting of cash flows related to ‘forward starting’ transactions in the C 66.00 maturity ladder template

What are the exact requirements for the reporting of cash flows related to ‘forward starting’ transaction (transactions already agreed and valid as of the reporting date, yet producing both start and end cash flows in the future) in C 66.00 maturity ladder template? Would it be possible to report the start leg and end leg of a forward starting transaction in the same row?

  • 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_5154
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 04/12/2020

Reporting of interest-related cash flows in the C 66.00 maturity ladder template

What are the exact requirements for the reporting of interest-related flows in the C 66.00 maturity ladder template?

  • 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_5152
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 04/12/2020

Reporting of cash flows related to ‘extraordinary’ and one-off transactions in the C 66.00 maturity ladder template

What are the conditions for inclusion of cash flows related to ‘extraordinary’ and one-off transactions in the C 66.00 maturity ladder template?

  • 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_5151
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 04/12/2020

Reporting of ceded assets, that are part of a cover pool, in asset encumbrance.

Shall cell F32.04, r100, c040 be opened?

  • 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_5142
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 04/12/2020

EBA validation rule v4859_m: [C 24.00 (c030;040;050;060)] {r100} <= {r030} + {r060} + {r080} + {r090}

The prevailing implementing technical standards (Commission Implementing Regulation (EU) No 680/2014 of 16th April 2014 as amended by Commission Implementing Regulation (EU) No 2018/1627 of 9th October 2018 provide guidance, about the breakdown of figures relevant for the calculation of market risk, when using internal models. In the Annex II point 5.7.1 - General Remarks, is stated: "142. Generally, the reporting depends on the structure of the model of the institutions whether they report the figures for general and specific risk separately or together. The same holds true for the decomposition of the VAR /Stress-Var into the risk categories (interest rate risk, equity risk, commodities risk and foreign exchange risk). An institution can resign to report the decompositions mentioned above if it proves that a reporting of these figures would be unduly burdensome". Considering that the separate reporting of specific and generic risk, for equity instruments, would be unduly burdensome and low material, it is not foreseen by the structure of the model applied, therefore we judge that total amounts for general and specific risk should be checked against total positions only. This feature has never been reviewed during the assessments and extensions of the model.

  • 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_5082
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 04/12/2020

Counterparty breakdown - classification based by immediate counterparty

What is definition of jointly incurred exposures for the purposes of FinREP (Annex V par. 43) ? Are there examples? Can guarantors be regarded as obligors and thus the exposures guaranteed by them as jointly incurred exposures?

  • 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_5061
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 04/12/2020

C 70 treatment of multiple currencies

If on the same day for one counterparty, funds in one currency are maturing and new funds are obtained in another currency, should these be treated as new funds or rollovers on the C 70 total template? In the case where the maturing deposit is replaced by more than one new deposit and both have different initial maturities, should the amount in rollover be proportionally spread across both time buckets?

  • 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_5058
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 04/12/2020

Validation rules v2815_m to v2823_m between FINREP and AE

Are validation rules v2815_m to v2823_m between FinRep and AssetEncumbrance plausible if an institution has to report significant portfolios as 'held for sale' in accordance with IFRS 5, in particular taking into account the intention of AssetEncumbrance?

  • 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_4744
  • Topic: Supervisory reporting - Asset Encumbrance
  • Date of submission:
  • Published as final Q&A: 04/12/2020

Definition of an "exposure" in C 15 instructions

We would like to clarify C 15 reporting requirements. Especially which exposures should be included here in case there is immovable property collateral.

  • 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_4892
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 04/12/2020