Search for Q&As

Enquirers can use various factors to search for a Q&A:

  • These include searching by the Q&A ID; legal reference, date submitted, technical standard / guideline, or by keyword if known.
  • Searches can be extended to more than one legal act, topic, technical standard or guidelines by making multiple selections (i.e. pressing 'Ctrl' on your keyboard, and selecting the relevant ones from the drop-down lists by left mouse-click).

Disclaimer:

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.

Final Q&As Q&As under review Rejected Q&As Archived Q&As All Q&As

List of Q&A's

Completion of the Z08.02 Template

In Z_08.02, are we expected to map operational assets to external services or only to intra-entity services?  If we are expected to map operational assets to external services, for external services which relate to support we receive on IT systems, should columns 0030, 0080, 0040 and 0050 be populated with data related to the respective IT system or should they be left blank? Additionally, if we report a service related to physical transportation of cash, should columns 0030, 0080, 0040 and 0050 be left blank considering that we don't need any asset to receive the service from the external provider?    

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7927
  • Topic: BRRD Reporting
  • Date of submission:

Template Z08.02: Reporting of applications owned and operated by affiliated service providers

Where a reporting entity receives services from an affiliated entity and relies on applications that are owned, managed and operated by that affiliated service provider, should those applications be reported in template Z08.02 by the receiving entity?Alternatively, should template Z08.02 be limited to operational assets that are owned, managed or directly controlled by the reporting entity, with dependencies on affiliate-owned applications being reflected through the relevant service provider and outsourcing/inter-affiliate reporting templates?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7926
  • Topic: BRRD Reporting
  • Date of submission:

Definition of “Substitutability” of CCPs and the connected reporting of “Alternative Providers” for the purpose of the template Z 09.04 (RESOL II).

Should the concept of substitutability of CCPs, and consequently the identification of alternative providers to be reported in template Z 09.04, be interpreted restrictively, i.e. limited to CCPs or intermediaries that are capable of providing an equivalent clearing service for the same trading venue and/or market(s)? Or should a broader interpretation of substitutability be applied, focusing on the economic function, business and regulatory objectives as well as the post-trade nature of the clearing service, under which a CCP might be substitutable not only by a concurrent CCP active on the same market, but also by: the substitution of the entire trade value chain (e.g. trading venue – CCP – CSD or trading venue – CSD); or the use of an intermediary/broker capable of rerouting either the trading and clearing activity or the transactions executed on behalf of the reporting institution through alternative FMIs, provided that such arrangements achieve a comparable economic and functional outcome for the reporting institution.

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7912
  • Topic: BRRD Reporting
  • Date of submission:

RESOL1 - how balance of cash collateral received as variation margin for intra group Repurchase Agreements should be reported in Z11.00 and Z02.00

How cash collateral received as variation margin for intragroup Repo trades be reported in Z11.00 and Z02.00 when the underlying Repo has already matured? What should be the insolvency ranking (c0030) of this balance intragroup variation margin in Z11.00?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7895
  • Topic: BRRD Reporting
  • Date of submission:

Application and interpretation of the 50% / 80% weighting of positive changes under IRRBB SOT

How should Article 4(l) of the RTS on Supervisory Outlier Tests be interpreted in relation to the weighting of positive changes, in particular regarding: Whether the 80% weighting factor and associated cap should apply to EUR, given that EUR is not an ERM II currency. Whether the reference to “absolute value of negative changes in EUR or ERM II currencies” when calculating the cap should be interpreted as a sum of negative changes across all currencies or as a minimum reference between EUR and ERM II currency buckets. Whether the weighting of positive changes should be applied at the individual risk level or at an aggregated level?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2026_7886
  • Topic: Interest Rate Risk for Banking Book (IRRBB)
  • Date of submission:

Geographical allocation of exposures arising from synthetic securitisations for the purposes of the Countercyclical Capital Buffer (CCB)

For synthetic securitisations where the originator: retains certain securitisation tranches (e.g. senior or mezzanine tranche), obtains funded credit protection for part of the junior risk, and obtains unfunded credit protection for another part of the junior risk, how should the geographical location of the originator’s remaining exposures be determined for purposes of CCB calculation? Specifically: Should all exposures arising from the securitisation—whether securitisation exposures or CRM‑transformed exposures—be allocated according to Article 4 of Delegated Regulation (EU) 1152/2014, based solely on the obligors of the underlying exposures?  Or should the following differentiated approach apply: retained securitisation exposures: allocation under Article 4 DelVO 1152/2014. funded protection: no remaining exposure → no CCB geographical allocation; unfunded protection: exposure is no longer a securitisation exposure but a CRM‑transformed credit exposure; Should the geographical allocation follow the logic of Q&A 2016_3050 (pre‑CRM exposure = underlying obligors = allocation according to Article 4 DelVO 1152/2014 the same as for the retained securitisation exposure), or                the standard CRM logic for credit exposures (location of the protection provider instead of location of the underlyings)?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 1152/2014 - RTS on the identification of the geographical location of relevant credit exposures for institution-specific countercyclical capital buffer rate
  • ID: 2026_7830
  • Topic: Other issues
  • Date of submission:

Where to classify Tier2 Subordinated issuances when they loss their MREL computability due to an earlier call (already announced on markets)

When a subordinated issuance loses its MREL eligibility due to an early call that has been announced to the market but not yet executed, should it be reported in row r037x or r0531? Additionally, if r037x is selected, should the Insolvency Ranking be adjusted accordingly under Spanish regulation?

  • Legal act: Directive 2014/59/EU (BRRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2025/2303 - ITS on Resolution Planning Reporting
  • ID: 2026_7797
  • Topic: BRRD Reporting
  • Date of submission:

Volume and value of credit transfers and instant credit transfers, and charges for credit transfers, instant credit transfers and payment accounts

Concerning Template ‘ S3.00 – Number of payment accounts and total charges’ of the draft ITS: should the amount of these fees be reported including tax or excluding tax? 

  • Legal act: Regulation (EU) 2024/886 (IPR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2025_7629
  • Topic: Instant payments
  • Date of submission:

fully and completely secured by mortgages for the purpose of the deduction of non performing exposures

In the context of the CRR3 and the application of the deduction of non-performing exposure from Common Equity Tier 1 as per article 47c, we would like to clarify the requirements of “ fully and completely secured by mortgages” in order to determine the "secured part of a non-performing exposure".

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7503
  • Topic: Credit risk
  • Date of submission:

Payment account definition

Does an account provided by a payment service provider, linked to a payment instrument that can be used to make payment transactions to [certain] third parties (e.g. merchants) from that account, as well as to withdraw cash from that account (e.g. from an ATM) and receive incoming payments in the respective account from the same payment users to which the funds were transferred (i.e, refunds from merchants) fall under the definition of a payment account in accordance with PSD2, even if the respective account cannot receive funds from third parties via credit transfers?  

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7463
  • Topic: Other topics
  • Date of submission:

Application of PSD2 provisions to the issuance and redemption of electronic money tokens

1) An EMI is acting solely as an issuer of EMTs ("EMTI") to its customers - crypto asset service providers (CASPs), these then provide the EMTs to their retail customers to be used for cryptoassets trading. EMTI does not maintain any fiat currency payment account for CASPs, nor provide any cryptocurrency services to them within the meaning of Articles 60(4) and 62 of the MICAR. Does the issuance of EMTs lead to a contractual relationship between the EMT holder (CASP, to whom the EMT is issued) and the EMTI within the meaning of PSD2 and EMD2? Is this contract passed on to the subsequent EMT holders who will acquire the EMTs from CASPs? 2) What is the legal nature of the acts of issuance and redemption of the EMTs?3) Which provisions of PSD2, if any, apply to issuance and redemption of the EMTs?

  • Legal act: Regulation (EU) No 2023/1114 (MiCAR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7457
  • Topic: Authorisation of issuers of ARTs and EMTs (MiCAR)
  • Date of submission:

Calculation of the standardised total risk exposure amount or S-TREA under Article 92(25)

Does the calculation of standardised total risk exposure amount, or S-TREA, require Firms to recalculate RWAs for standardised approaches where modelled inputs have been used? Specifically, do CVA RWAs calculated using IMM modelled EADs need to be re-calculated using EADs that have not been derived using a modelled approach?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7429
  • Topic: Own funds
  • Date of submission:

Calculation of COH according to Article 20 vs. Art. 12 (1) Subparagraph 2

How exactly does the calculation of COH, AUM, ASA, DTF, NPR and TCD on the basis of IFR Article 12 (1) Subparagraph 2 differ from the general method for calculation COH in IFR Article 20?

  • Legal act: Regulation (EU) No 2019/2033 (IFR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2025_7359
  • Topic: Capital requirements
  • Date of submission:

emission allowances

Sentence 2 of paragraph 3 of Annex II CRR refers to point (11) of Section C of Annex I MiFID, i.e. to emission allowances. Does that mean that spot market emission allowances are to be treated as derivative contracts listed in Annex II, even though they are not derivative in character?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7255
  • Topic: Other issues
  • Date of submission:

Application of Instant Payment Regulation (IPR) to Securities Providers

Do you agree on the non-applicability of the obligation to provide instant credit transfers (within a time horizon of 10 seconds), introduced by IPR, to depositaries, custodians, and entities responsible for payments or local facility for foreign CIUs distributed in a Member State, based on the exclusion provided by article 3, paragraph 1, letter i), of directive 2015/2366 (PSD2)?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7249
  • Topic: Authorisation and registration
  • Date of submission:

Prudential treatment for exposures in leasing real estate under construction

Should exposures in "real estate under construction instrumental leasing" fall within the definition of ADC exposure of Article 4(78a) of Regulation (EU) No. 575/2013 as amended by Regulation (EU) No. 1623/2024, or instead be treated applying the RW provided for unsecured exposures towards the lessee?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7226
  • Topic: Credit risk
  • Date of submission:

Definition of ADC exposures

Should ADC exposures include exposures related to financing land acquisition for development and construction purposes or the development and construction of residential or commercial property for borrower’s own use?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7201
  • Topic: Credit risk
  • Date of submission:

Payment service user - both payer and payee

Can a payment service user be both payer and payee on a money remittance service?

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7184
  • Topic: Other topics
  • Date of submission:

Transactions executed via electronic mail (email)

Do transactions ordered by email and executed by an employee of the payment service provider, e.g., credit transfers orders sent from the e-mail address of the payer to the e-mail address of the payment service provider and executed accordingly qualify as transactions executed through a remote channel, at-distance channel or a payment instrument which may imply a risk of payment fraud or other abuses, pursuant to Article 69, Article 70, Article 72 and Article 97(1)(c) PSD2?

  • 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_7150
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:

Exclusion of cash withdrawal services from PSD2

Is it a prerequisite for an ATM operator,to qualify for the exemption of article 3(o), to co-operate with a Payment Service Provider (authorised within the EEA or with a relative passport where necessasry) offering payment service number 2 of the Annex 1 of the PSD2?  

  • Legal act: Directive 2015/2366/EU (PSD2)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2024_7136
  • Topic: Other topics
  • Date of submission: