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List of Q&A's

Components included in total gross annual earnings used for the calculation of gender pay gap

Should overtime pay awarded to staff members be included in their total gross annual remuneration for the purposes of calculating the gender pay gap? 

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2021/04 - Guidelines on sound remuneration policies under CRD (repealing EBA/GL/2015/22)
  • ID: 2024_7128
  • Topic: Remuneration
  • Date of submission:
  • Published as final Q&A: 25/10/2024

Simple Transparent and Standardised securitisation

How does the value-weighted average referred in Article 243.2.b)i) of CRR should be calculated?Should we:Option A: calculate first a “Loan to Value” average and then map it to the applicable value-weighted average according to CRR or;Option B: calculate a risk weighted average calculated from each exposure multiplied by its corresponding risk weight divided by the sum of the total exposure value?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6957
  • Topic: Securitisation and Covered Bonds
  • Date of submission:
  • Published as final Q&A: 25/10/2024

Card data (PAN) to be returned in AISP calls

Does the ASPSP have to return the card number (PAN) attached to a fetched payment account in case the user can access this data during a standard session with its ASPSP in the direct internet banking interface? In case of "YES", does the TPP that is fetching this data have to be PCI DSS certified, since this data has to be encrypted based on the PCI DSS requirements? Moreover, could be the "card number (PAN)" considered sensible, since it could be potentially used for fraud?

  • 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: 2023_6946
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 11/10/2024

Identify when EMD2 needs to be applied to vouchers/gift cards issued by an electronic money institution.

Do vouchers/gift cards issued by an electronic money institution (EMI) to top-up an e-money account (managed by the EMI itself) in order to purchase on an e-commerce platform: i) goods and services sold directly by companies belonging to the same corporate group of the EMI (thus falling out of the scope of PSD2, encompassing the exemption provided for intra-group transactions in Article 3(1)(n) of the PSD2); ii) goods and services of third-party merchants, have to be qualified as e-money at the time of issuing (i.e. sale) or - given the possible indefinite use of the funds - they acquire that status only at the moment they are used to purchase goods and services from third-party merchants on the e-commerce platform?

  • Legal act: Directive 2009/110/EC (EMD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6736
  • Topic: Not applicable
  • Date of submission:
  • Published as final Q&A: 11/10/2024

Payment account

What is the difference between payment account, e-money account and a bank account (account held at the credit institution) in terms of allowed transactions? Is it possible to hold funds on a payment account to make future payment transactions?Is it possible to receive the salary on a payment account, if this account is not an e-money account or an account held by a credit institution, which constitute a deposit or other repayable fund?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6611
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 11/10/2024

The definition of payment services and in particular the definition of execution of payment transaction in relation to netting centers

1. Is an (international) non-profit association, acting as netting centre in the framework of a multilateral netting agreement entered into between its members, that receives and forward funds to and from its members through a bank account opened in its name deemed to carry out payment services falling within the scope of Article 4(3) of Directive (EU) 2015/2366 of the European Parliament and of the Council of 25 November 2015 on payment services in the internal market, amending Directives 2002/65/EC, 2009/110/EC and 2013/36/EU and Regulation (EU) No 1093/2010, and repealing Directive 2007/64/EC ('PSD2') (e.g. the execution of payment transaction or money remittance)?2. If the netting center is deemed to carry out payment services, can the netting centre rely on exclusion of Article 3(n) of PSD2, i.e. 'payment transactions and related services between a parent undertaking and its subsidiary or between subsidiaries of the same parent undertaking, without any intermediary intervention by a payment service provider other than an undertaking belonging to the same group'?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6489
  • Topic: Authorisation and registration
  • Date of submission:
  • Published as final Q&A: 11/10/2024

Exclusion of cash withdrawal services from PSD2

If a provider offers cash ATM withdrawal services, not acting on behalf of one or more card issuers but rather through an agreement with the main payment circuits, shall this type of provision be considered exempt from the PSD2?  

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6360
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 11/10/2024

Unterstützungsfaktor für Infrastrukturprojekte - Supporting factor for infrastructure projects

Können sowohl der in Artikel 501 CRR genannte Faktor zur Unterstützung von KMU als auch der in Artikel 501a CRR genannte Faktor zur Unterstützung von Infrastruktur auf eine Risikoposition angewandt werden?Can the supporting factor for SMEs referred to in Article 501 CRR and the infrastructure supporting factor referred to in Article 501a CRR both be applied to an exposure?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5551
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 11/10/2024

Treatment of two-leg derivatives with respect to rate type and currency

What is the expected representation for two-legs derivatives in the templates "BREAKDOWN OF SENSITIVITY ESTIMATES (J 02.00, J 03.00 and J 04.00)" and REPRICING CASH FLOWS (J 05.00, J 06.00 and J 07.00)?

  • 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: 2024_7073
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as final Q&A: 27/09/2024

Breakdown of currencies to be reported

What is the expected breakdown by currencies for the reporting of template J.01.00 and for the reporting of the other J templates [(J 02.00, J 03.00 and J 04.00), (J 05.00, J 06.00 and J 07.00), (J 08.00 and J 09.00) and (J 10.00 and J 11.00)] in the case that for J 01.00 the bank includes other currencies in addition to the minimum “material currencies” as defined in Article 1(3) of Delegated Regulation (EU) 2024/856 when reporting the aggregation of “all currencies”? Let us consider, for example, the case of a bank on which on a consolidated level three currencies (EUR, USD, GBP) are identified as “material currencies”, but the bank includes, on a voluntary basis, other currencies (e.g. MXN and BRL) for the calculation of the SOT, as it is considered in the bank’s internal management systems. Must the bank provide the breakdown by currencies for the J templates only for the “material currencies” (EUR, USD, GBP) or as well for the other “non-material currencies” (MXN and BRL)? 

  • 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: 2024_7148
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:
  • Published as final Q&A: 27/09/2024

Revocation of ASPSP's Exemption from the Contingency Mechanism due to Prolonged Service Disruption

In a scenario where an incident lasting more than two consecutive weeks preventing Payment Service Users (PSUs) from initiating their payments through a dedicated interface, considering that the Account Servicing Payment Service Provider (ASPSP) has an exemption from the contingency mechanism under Regulation (EU) 2018/389, and the National Competent Authority (NCA) has been notified about the incident: Should the National Competent Authority (NCA) revoke the ASPSP's exemption from the contingency mechanism?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2018/07 - Guidelines on the exemption from the contingency mechanism under Regulation (EU) 2018/389
  • ID: 2024_7103
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 27/09/2024

Criteria for selecting the operations to be included in the calculation of fraud rates for the transaction risk analysis (TRA) exemption

Which of the following would be the correct temporal criterion for selecting the unauthorized transactions to be included in the numerator of the fraud rates calculated for the transactions risk analysis (TRA) exemption? a) the transaction date, i.e., the date on which the transaction was executed regardless of the date on which it is classified as unauthorized or fraudulent b) the registration date, i.e., the date on which the transaction is registered as unauthorized or fraudulent regardless of the date on which it was carried out 

  • 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: 2024_6989
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 27/09/2024

Secure corporate payment processes and protocols and inactivity time period

May the period time of inactivity required by the (EU) 2018/389 - RTS on strong customer authentication and secure communication (hereinafter: RTS on SCA & CSC) Article 4 (3) (d) be changed from 5 minutes to 20 minutes if the exemption based on Article 17 of RTS on SCA & CSC has been granted by the competent authority to the Payment service provider?

  • 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: 2023_6949
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 27/09/2024

Disclosures in case of lack of label in EPCs

What shall be reported in columns h-n in case local EPCs do not present labels in the form of letters (A-G), but only level of energy efficiency? Shall these columns be left blank or “0” can be disclosed? Is it acceptable that the banks remove these columns from the template and do not disclose them at all? In addition, what shall be reported in this case in columns o and p? Column “o” is named as “Without EPC label of collateral” and it may indicate that the values to be disclosed in this column refer to the information in columns h-n.  

  • 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: 2024_7013
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 20/09/2024

Alignment of total funding between FINREP F01.02 and COREP C67.00

What is the correct approach regarding the alignment between the FINREP F01.02 and COREP C67.00 templates as required by the AMM ITS since (1) the scope of consolidation might be different between the two reports and (2) different netting rules can apply between the two reports?

  • 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_6956
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 20/09/2024

Maturity weighting of gross JTD amounts to calculate net JTD amounts

Are the maturity weighting of gross JTD amounts and three months floor of Art. 325x(3) applicable only to gross JTD amounts in cases where no offsetting is possible or are they applicable more generally to all gross JTD amounts?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7129
  • Topic: Market risk
  • Date of submission:
  • Published as final Q&A: 13/09/2024

What amount to be reported for repos and reverse repos in NSFR?

What’s the appropriate definition of 'accounting value' of repos and reverse repos in UK, for NSFR reporting purposes?  We have identified several potential interpretations, which include: 1) The cash nominal at the value date of the transaction (referred to as 'outstanding').2) The cash nominal at the value date, plus the accrued interests.3) The outstanding value (as defined in point 1), plus all interests flows (both accrued and non-accrued).4) The outstanding value (as defined in point 1) multiplied by a discount factor, plus the interests flows multiplied by a discount factor. This could be considered a form of cash fair value. When netting repos and reverse repos of the same counterparty together under the appropriate conditions, for NSFR purpose, should we use the same 'accounting value' to determine if the net position falls under a repo or a reverse?  Any guidance you can provide on this matter would be greatly appreciated.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2024_7034
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 30/08/2024

Annex XI, INSTRUCTIONS FOR REPORTING ON LEVERAGE, C43 template {0040;0020} & {0050;0020}

Where should the cash collateral receivables on derivative transactions be disclosed in template C43

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/11 - Guidelines on disclosure requirements under Part Eight of CRR
  • ID: 2024_7033
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 30/08/2024

List of IEA Sectors in Column a vs List of IEA Sectors in the EBA3.3 Annotated Table Layout for ESG

Based on the Excel version of Template 3 (Annex XXXIX), there are 8 sectors explicitly listed in column a (Sector / IEA Sector): Power Fossil fuel combustion Automative Aviation Maritime transport Cement, clinker and lime production Iron and steel, coke, and metal ore production Chemicals And referring to the ITS Annex XL - Instructions for disclosure of ESG risks - Paragraph 19(a), it also mentions that there are 8 mandatory minimum set of sectors: 19. Institutions shall disclose in this template: a. Columns a and b: these columns include the sectors (IEA sectors in column a) under which rows 1-8 lists the mandatory minimum set of sectors, and ..... However, in the "Annotated Table Layout 330-P1-ESG 3.3.xlsx" and in the data dictionary / DPM, downloaded from EBA's website, there are only 7 values mentioned for the IEA sector -  The <Key value> (combination of all <Key value> columns when more than one) must uniquely specify each row. Value restricted to subset [CT55]: (CT:x83) Carbon intensive firms (CT:x84) 1. Power (CT:x85) 2. Fossil fuel combustion (CT:x86) 3. Automotive (CT:x87) 4. Aviation (CT:x88) 5. Maritime transport (CT:x89) 6. Cement, clinker and lime production (CT:x90) 7. Iron and steel, coke, and metal ore production   The IEA Sector named "Chemicals" is not included in the EBA 3.3 list of values. Will either the Excel version and ITS be updated to remove "Chemicals" from the list of mandatory minimum set of sectors or the "Annotated Table Layout for ESG" be updated to include "Chemicals"?  

  • 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: 2024_7085
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 26/07/2024

Template 5 - Reporting of gross carrying amount of exposures sensitive to chronic, acute, chronic and acute climate change events

In Template 5, should the gross carrying amount of exposures in column j (of which exposures sensitive to impact from both from chronic and acute climate change events) be reported also in column h (Of which exposures sensitive to impact from chronic climate change events) and column i (Of which exposures sensitive to impact from acute climate change events) or is the gross carrying amount of exposures reported in these 3 columns mutually exclusive?  

  • 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: 2024_7080
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 26/07/2024