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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

Counterparty classification of the ESM and the ESFS

How are ESM and ESFS to be classified for FINREP – as government or as non-financial corporations?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_4282
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 06/09/2019

C 66.00, validation rule v5903_s

In an environment of negative (money market indexing) interest rates this rule may not be applicable.

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_4193
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 06/09/2019

Conditions for the filling of template C 33.00

If a bank will move to IFRS9 accounting standards starting from 1 July 2018, the first date for the Corep reporting under IFRS9 will be 30 September 2018. Therefore, at 30 June 2018 the new logic of the IFRS9 accounting portfolios is not available in data systems and it would be difficult to complete the new model C 33.00. We would like to know if the bank still need to fill in the template C 33.00 at 30 June 2018 and, if so, what logic it has to use.

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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_4072
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 06/09/2019

Double counting of intra-group funding in C68.00

"In C68.00 Unsecured wholesale funding (row 110) should be split per product type: - of which loans and deposits from financial customers (row 120) - of which loans and deposits from non-financial customers (row 130) - of which loans and deposits from intra-group entities (row 140) Should intragroup funding be reported exclusively in row 140? Or should it be reported in row 140 AND in row 120/130 depending if the intragroup entity is a financial or a non-financial customer? The same question applies to the split of wholesale 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: 2018_3962
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 06/09/2019

Incorrect validation rule v4456_m

The validation rule v4456_m is not correctly defined in the taxonomy 2.7. Prerequisites are following: C 47.00 and C 43.00.a and C 43.00.b and C 43.00.c It means that all tables have to be reported. However a bank with a standardised approach to credit risk do not report table C 43.00.c. Consequently the rule can not be applied. In theory a bank can have no data for the table C 43.00.a as well.

  • 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_3950
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 06/09/2019

Is the scope of the RTS on strong customer authentication (SCA) and secure communication one-leg or two-leg?

Does the PSD2 requirement on SCA, and subsequently the detailed requirements in the RTS on SCA including the practical usage of the allowed exemptions, apply also to one-leg transactions, with regards to:Transactions with the payer’s payment service providers (PSP) outside the EEA (credit transfers as well as card-based payments)?Credit transfers with the payer’s PSP inside the EEA and the payee’s PSP outside the EEA?Card-based payments with the payer’s PSP (the issuer) inside the EEA and the payee’s PSP (the acquirer) outside the EEA, when the non-EEA acquirer do support SCA?Card-based payments with the payer’s PSP (the issuer) inside the EEA and the payee’s PSP (the acquirer) outside the EEA, when the non-EEA acquirer does not support 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_4233
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 06/09/2019

The Implementation of the electronic communications exclusion in the voiced-based premium rate services market

Considering the organisation of the voiced-based premium rate services market, and considering the interpretations proposed for the electronic communications exclusion (ECE) in the different countries, as far as a payment transaction complies with the conditions imposed by the ECE, does the ECE apply to the whole value chain, and therefore, all the providers of electronic communications networks or services involved in payment transactions covered by the ECE should not have to register as payment institutions or agents for these operations?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4181
  • Topic: Other topics
  • Date of submission:
  • Published as final Q&A: 06/09/2019

Geographical scope of application of the RTS on strong customer authentication (SCA) and secure communication requirements – ‘Two-leg’ transactions

Is it necessary that issuer, acquirer, cardholder and merchant be all located in the EEA for the RTS on SCA requirements to apply to two-leg transactions?May the issuer use the merchant’s location as a proxy (in lieu of the acquirer’s location)?

  • 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_4030
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 06/09/2019

IFRS 9 Transitional Arrangements - Business Combination

There is a business combination between banks which decided to apply the static and dynamic phase in the arrangements envisaged by Article 473a CRR.1) How should the static phase-in arrangements envisaged by Article 473a CRR apply on the consolidated basis?2) How should the dynamic phase-in arrangements envisaged by Article 473a CRR apply on the consolidated basis?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4391
  • Topic: Accounting and auditing
  • Date of submission:
  • Published as final Q&A: 09/08/2019

What is considered as a dedicated interface

Payment Service Users (PSUs) communicate with an account servicing payment service provider (ASPSP) via Web using HTTP while mobile PSUs and Third Party Providers (TPPs) via REST Application Programming Interfaces (APIs) but in all cases the processing is done by the same back-end server using the same credentials, authorisations and business logic. In the case of mobile and TPP channels, the APIs are similar and are exposed from the same ASPSP’s gateway. Any issue in the back-end server will result in downtime for all channels. Clarification is required whether this solution is considered as a dedicated interface or not.

  • 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_4681
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 09/08/2019

Inclusion of time taken for SCA in the performance KPI

Does the Key Performance Indicator (KPI) for the performance of the dedicated interface include the time taken for conducting 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: 2019_4661
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 09/08/2019

Contactless transactions - SCA

Does the cumulative count / authorised sum amount apply to any contactless authorisation request, regardless if the request was approved or not?

  • 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_4230
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 09/08/2019

SCA at vending machines without PIN pad

Do transactions at vending machines without PIN pad require 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_4057
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 09/08/2019

Review of security measures

When an issuer delegates strong customer authentication (SCA) to a third-party (e.g. a smartphone manufacturer), what are the requirements for such delegation? Should the issuer conduct an evaluation of the technical features and security of third-party’s devices and solutions?

  • 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_4047
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 09/08/2019

Treatment of failed SRT under Traditional Securitisation

In case the significant credit risk cannot be considered to have been transferred according to 244 of Regulation (EU) No 575/2013 as amended by Regulation (EU) 2017/2401, but the exposures had been already derecognised from the bank's balance sheet, shall the bank continue to calculate the RWA for the securitised exposures as if they were never securitised? Does it mean that no RWA will be calculated for the securitisation position?  Additionally, if the exposures have been securitised against cash, and the cash invested in new loan, would RWA be calculated for these new loans

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2018_4207
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 26/07/2019

Timely payment requirement for unfunded credit protection provided under credit risk insurance policies

Does unfunded credit protection - which a bank has purchased in order to hedge a loan exposure and which provides the protection-seller with the contractual right to compensate credit losses according to the original scheduled payment dates of the hedged loan - fulfil the timely payment requirement for unfunded credit protection in a situation where the loan becomes due and payable prior to the original scheduled payment dates?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2017_3576
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 26/07/2019

Proposals for mortgage credit extension described in Article 14 of the Directive 2014/17/EU as off-balance sheet exposures

Are the binding proposals for mortgage credit extension described in Article 14 of the Directive 2014/17/EU off-balance sheet exposures according to Annex I CRR?Should FINREP,COREP reporting include such binding proposals for mortgage credit extension?

  • 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_3376
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 26/07/2019

EBA ITS package for 2019 benchmarking exercise (Annex V, section 2, FX instruments)

What is the correct interpretation of instrument No.40?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2016/2070 - ITS on Supervisory Reporting (for benchmarking the internal approaches) (as amended)
  • ID: 2018_4428
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 26/07/2019

Supervisory Benchmarking - Alternative risk weight

How shall mortgage portfolios for which - based on Art. 230 (3) CRR when the conditions of Art. 199 (6) CRR are satisfied - an alternative risk weight (e.g. 50% for commercial real estate) is used, be reported in the benchmarking exercise. Or should these exposures where no PD or LGD estimation is available for regulatory purposes be exempted from the reporting.

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2017_3222
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 26/07/2019

Annex I Template C101.00 - Sovereigns

Clarifications around which entities to include for those identified by a bloomberg ticker referencing a Sovereign

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
  • ID: 2017_3197
  • Topic: Supervisory reporting - Supervisory Benchmarking
  • Date of submission:
  • Published as final Q&A: 26/07/2019