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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.

List of Q&A's

Staff costs

Do imputed staff costs count as part of staff costs in accordance with Article 18(1)(f) of Regulation (EU) 2022/2554 in conjunction with Article 7(1)(c) Delegated Regulation (EU) 2024/1772 and Article 4(e) Delegated Regulation (EU) 2025/301 and must, therefore, be reported as part of gross direct and indirect costs and losses of an incident?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2024/1772 - RTS on the classification of ICT-related incidents and cyber threats

Definition and scope of ICT services

What is the correct reading of Article 3 (21) and Recital 63, Article 2 and Article 58(2) of Regulation (EU) No. (EU) 2022/2554 (DORA Reg) in combination with  the COM/2023/0365 European Commission Report on the review of Directive 2015/2366/EU ?

  • Legal act: Regulation (EU) No 2022/2554 (DORA Reg)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable