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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

Fair value hierarchy: Financial instruments at fair value (F14)

Can you provide more guidance on the amounts to be reported for “Change in fair value for the period” and “Accumulated change in fair value before taxes” in particular for derivatives falling under netting agreement and recognized with accounting offsetting?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/451 – ITS on supervisory reporting of institutions (repealed)
  • ID: 2024_7105
  • Topic: Supervisory reporting
  • Date of submission:
  • Published as final Q&A: 14/03/2025

MREL-REPORTING OF THE IMPACT OF GENERAL PRIOR PERMISSION

With reference to the Q&A 6852, we kindly request clarification on the appropriate logic to utilize when adding the amounts of the unused portion of the GPP for the rows in Template M 01.00, specifically rows 0250 to 0290. We would greatly appreciate if you could provide guidance on the correct allocation of the unused amount for rows 0260, 0270, 0280, 0285, and 0290. Given that the GPP has a duration of one year, it is our understanding that the unused amount should be accounted for solely in rows 0250 and 0285, as per convention.

  • 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: 2024_7153
  • Topic: BRRD Reporting
  • Date of submission:
  • Published as final Q&A: 14/03/2025

Definition and scope of Asset Under Management

Are assets for which the investment firm provides generic advice services (outside of the MIFID authorisation scope)  to be included in the K-AUM calculation?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7223
  • Topic: K-factor requirements
  • Date of submission:
  • Published as final Q&A: 14/03/2025

Other commitments received - calculation of guarantee amounts

On report F09.02, banks are asked to report guarantees received as collateral, partly in column 0010 and partly in column 0020. Where some questions have been answered in earlier Q&As, some questions remain: Based on Q&A 2013_214, guarantees received on off-balance sheet exposures should be reported as "Other Commitments Received". These are reported in F09.02 Col0020.Based on Q&A 2023_6773, in F09.02 Col0010, guarantees are considered by ignoring other collaterals.Should other collaterals be considered in calculating the amount reported in column 0020? Along the same lines, how should calculations work for both columns 0010 and 0020 if multiple guarantees are received? Within the same group of exposures and its/their contractually linked collaterals/guarantees, should they all be calculated separately and independently, ignoring the existence of other guarantees within the same group similar to the way other collaterals in the same group are ignored?The ITS states that "For other commitments received, the nominal amount shall be the total amount committed by the other party in the transaction." is to be reported in column 0020.  Does this also apply in the case whereby a guarantee is received to secure an (off-balance) exposures? In other words, should it be capped at the Off-Balance Exposure Amount or not?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions
  • ID: 2025_7301
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/03/2025

Counterparty classification of CCP

Where counterparty sector breakdown applies, it is required more guidance on how to classify a CCP which have the banking license. For instance, in template F10, where should we report derivatives positions we have with a QCCP which at the same time is (i) a clearing house and (ii) a credit institution (included in the list of ECB’s supervised banks)? We face the ambiguity in classification in further reporting frameworks both supranational (e.g. G-SIB data collection exercise, FSB)  and local (i.e. Circolare 262 Banca d’Italia on Financial Statements).

  • 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 (repealed)
  • ID: 2025_7316
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/03/2025

Definition of ‘subordinated liabilities’ for FINREP reporting

What should be considered as ‘subordinated liabilities’’ for financial reporting purposes in FINREP template 8.2? Does definition of “subordinated liabilities” include also MREL instruments that do not qualify as Common Equity Tier 1, Additional Tier 1 or Tier 2 items meaning and have characteristics defined in the Article 72b(2) of CRR? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutions
  • ID: 2025_7337
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/03/2025

Presentation of fully matured loans and deposits in templates F05.01 and F08.01

Could you please clarify how fully matured loans and deposits should be presented in templates F05.01 and F08.01?

  • 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 (repealed)
  • ID: 2025_7344
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/03/2025

Own secured debt issues in Top 10 - C71.00

Does the secured debt instruments issued by the reporting institution (own issues retained) be reported in the Top10 in C71?

  • 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 (repealed)
  • ID: 2024_7090
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 21/02/2025

Temporary unavailable (blocked) deposits

Could you please clarify how temporary unavailable (blocked) deposits should be presented?

  • 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: 2024_7088
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 21/02/2025

FINREP Template F01.01

We would like to seek clarification regarding the classification of repurchase agreements (repos) in the context of the FINREP reporting framework.Specifically, we am inquiring whether repurchase agreements with a maturity of less than or equal to one day, where the counterparty is a credit institution, can be reported under row 0040 (Other demand deposits) in report F01.01.

  • 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 (repealed)
  • ID: 2024_7241
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2025

Reporting of customer portfolios managed on a discretionary basis

According to Annex V, Part 2, paragraph 285 (a) of Commission Implementing Regulation (EU) 2021/451 (ITS): '‘'Asset management’ shall refer to assets belonging directly to the customers, for which the institution is providing management.” Since these assets belong to the customers, they are generally not recognized in the balance sheet of the credit institution. It is not clear however if the cash deposited by customers that the institution manages on a discretionary basis should be recognized as a liability. Additionally, if this account would have a negative balance, an asset might be recognized. 

  • 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 (repealed)
  • ID: 2024_7224
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 14/02/2025

Direct contributions to reserves from shareholders

Which conditions should direct contributions to reserves from shareholders meet when assessing their conformity with the criteria contained in the last subparagraph of Article 26(1) CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7256
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 07/02/2025

Conditions for increasing the margin period of risk (MPOR) used for the exposure value of netting sets with margin agreements.

Article 285 paragraph 3(b) references “OTC derivative that cannot be easily replaced”. By definition “OTC derivative” does not include listed / exchange trades derivatives.  The final sentence of paragraph 3 states “An institution shall consider whether trades or securities it holds as collateral are concentrated in a particular counterparty and if that counterparty exited the market precipitously whether the institution would be able to replace those trades or securities.” Is this is a clarification of 3(b) meaning that the reference to “replace those trades” would be in relation to OTC derivatives? Or alternatively is the reference to “replace those trades” broader than OTC derivatives?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7229
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 31/01/2025

Application of article 378 for free delivery transactions

Given the requirements of article 378 and 379 CRR II, shall the institution apply the article 378 also in case of free deliveries (disciplined by article 379) or should it be applied only to DVP transactions?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7119
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 31/01/2025

Seniority categories to use when offsetting the gross JTD amounts of short exposures and long exposures within the DRC calculations for non-securitisations 

Which set of seniority categories shall be utilised and how should they be ranked as the basis for offsetting the gross JTD amounts of short exposures and long exposures within the DRC calculations for non-securitisations? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7233
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 17/01/2025

Basis of calculation for the DRC for non-securitisations and SBM-CSR for non-securitisations – Individual ‘issuers’/‘obligors’ or ‘group of issuers/obligors’?

Do the calculations of the DRC for non-securitisations and SBM-CSR for non-securitisations have to be based on the individual ‘issuers’/‘obligors’, or could these calculations alternatively be based on the concept of a ‘group of issuers/obligors’ consisting of e.g. a conglomerate (and e.g. represented by an ‘ultimate parent’ corresponding to the ‘head of group’ or ‘parent company’)?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7230
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 17/01/2025

Basis of calculation for the DRC for non-securitisations and SBM-CSR for non-securitisations - instruments guaranteed by a guarantor

In the case of instruments guaranteed by a guarantor (such as guaranteed bonds), can that guarantor be used as the basis for calculating the DRC for non-securitisations and the SBM-CSR for non-securitisations? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7231
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 17/01/2025

Vega general interest rate risk and credit spread risk factors

For credit instruments that include issuer-specific optionality, do both general interest rate vega and credit spread vega risk factors need to be considered as part of the SBM? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7232
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 17/01/2025

Scope of public offering

"Question: Regarding ARTs or EMTs under MiCAR, what services provided in or into the EU constitute an offering to the public, a seeking admission to trading or a placing of an ART or EMT?

  • Legal act: Regulation (EU) No 2023/1114 (MiCAR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7185
  • Topic: Scope and definitions (MiCAR)
  • Date of submission:
  • Published as final Q&A: 17/01/2025

Safeguarding with a credit institition in a third country

May a PI authorised and operating in an EU Member State use a credit institution based in a third country (e.g. UK) for the purpose of safeguarding funds in accordance with Art. 10(1)(a) of PSD2?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6882
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 17/01/2025