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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

Delegation of 2-Factor Authentication (2FA) to PISP, AISP or other third party

Where a Payment Service Provider (PSP) is providing financial services via a third party application - either through a Payment Initiation Services Provider (PISP), Account Information Service Provider (AISP) or by providing embedded financial products or banking as a service solutions (i.e. financial services via an Application Programming Interface (API)) - is it permitted for the PSP to delegate the application of 2-Factor Authentication (2FA) to the third party?

  • 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: 2020_5643
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 24/09/2021

Meaning of ‘intragroup’ for the purpose of reporting in COREP template C 67.00

What is the scope of ‘intragroup counterparties’ for the purposes of classification of funding in COREP template C 67.00, column 050 (Product Type)? Is particular, can funding from a parent entity in a third country be considered ‘intragroup’?

  • 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Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 680/2014 - ITS on supervisory reporting of institutions (repealed)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: 2020_5638
  • Topic: Supervisory reporting - Liquidity (LCR, NSFR, AMM)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

v3078_m - Maximum Amount of Guarantee Given

Should the maximum amount of guarantee given reported in F_09.02 be capped at the carrying amount or nominal amount after deduction of provisions of the related exposure?

  • 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: 2020_5634
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

Collateral obtained by taking possession: Classification as Residential or Commercial

Clarification of the applicable criteria for the classification of foreclosed asset as Residential or Commercial in FINREP templates

  • 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: 2020_5632
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 30/04/2021

Treatment of non-performing exposures underlying a CIU

Could you clarify if non-performing exposures underlying a CIU should be subject to deductions in accordance with point (m) of Article 36(1) of CRR when using the look-through approach in accordance with Article 132a(1) of CRR or the mandate based approach in accordance with Article 132a(2) of CRR?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5629
  • Topic: Credit risk
  • Date of submission:
  • Published as final Q&A: 15/07/2022

Is the activity of pension fund administrators included in the "Portfolio management and advice" and thus, pension fund administrators qualify as financial institutions?

Is the activity of pension fund administrators included in the "Portfolio management and advice" and thus, pension fund administrators qualify as financial institutions?

  • Legal act: Directive 2013/36/EU (CRD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5628
  • Topic: Other issues
  • Date of submission:
  • Published as Rejected Q&A: 07/09/2022

Leverage Exposure Exclusion for guaranteed parts of Export Credit

Can a qualifying guarantee which meets the conditions of Article 429a(1)(f) only be used to reduce the Exposure of On Balance sheet Export related Credit (i.e. drawn amounts)? or can it also be applied to the Off Balance Sheet exposures related to Export Credits, such as the undrawn portion of an Export related facility?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Delegated Regulation (EU) 2015/62 - DR with regard to the leverage ratio
  • ID: 2020_5627
  • Topic: Leverage ratio
  • Date of submission:
  • Published as final Q&A: 15/07/2022

Association with the payment service user by means of a remote channel

Is it sufficient to use a company level knowledge element, in combination with a peronal posession element to associate a user of a business application with personalised security credentials such as authentication software or a knowledge element?

  • 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: 2020_5626
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 24/09/2021

Subcontractor of electronic money distributor

Does Article 3, paragraph 4 of Directive 2009/110/EC (EMD) mean that that a legal person acting as an electronic money distributor on behalf of an electronic money institution may enter into a contract with another legal person (subcontractor) for the execution of distribution and redeeming of electronic money? Or on the contrary, an electronic money distributor may not use subcontractors to distribute electronic money in the name of the electronic money institution under EU law?

  • Legal act: Directive 2009/110/EC (EMD)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5624
  • Topic: Not applicable
  • Date of submission:
  • Published as final Q&A: 18/03/2022

Application of SCA to issuing a payment instrument and tokenisation

Is strong customer authentication (SCA) required when a Payment Service Provider (PSP) issues a payment instrument or creates a token?

  • 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: 2020_5622
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 31/01/2023

Use of new technology for SCA

Is a Payment Services Provider (PSP) allowed to adopt innovative technologies for verifying Payment Services Users (PSUs) where the PSP maintains fraud levels below a certain threshold?

  • 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: 2020_5621
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 23/04/2021

Use of behavioural data for SCA

Can a Payment Service Provider (PSP) use behavioural data and auditable scores to apply Strong customer authentication (SCA) in a way that protects consumer privacy?

  • 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: 2020_5620
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 23/04/2021

Independence of the elements for SCA

Can a Payment Service Provider (PSP) apply Strong customer authentication (SCA) using elements from the same category provided that the elements are independent (i.e. breach of one does not compromise reliability of the other elements)?

  • 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: 2020_5619
  • Topic: Strong customer authentication and common and secure communication (incl. access)
  • Date of submission:
  • Published as final Q&A: 23/04/2021

Consideration of posted variation margin in LRCalc, when conditions of Article 429c (3) point (a) to (e) are met

Following the second sentence of Article 429c (3) provided cash collateral, which meets all the conditions set out in points (a) to (e) of Article 429c (3), shall be considered as variation margin posted to the counterparty and shall be included in the calculation of the replacement cost of the netting set under SA-CCR for leverage ratio. We kindly ask EBA for instructions how to consider cash variation margin provided to the counterparty, when points (a) to (e) of Article 429(c) are met, in LRCalc.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Draft ITS on Supervisory Reporting of Institutions
  • ID: 2020_5617
  • Topic: Supervisory reporting - Leverage ratio
  • Date of submission:
  • Published as final Q&A: 30/04/2021

Adding to own funds the unredeemed part of own funds.

When and under what conditions can the unredeemed part of own funds, for the redemption of which an institution had previously obtained a general prior permission from the competent authority in accordance with Article 77 and the second subparagraph of Article 78(1) of Regulation (EU) No 575/2013 (CRR), be included in own funds again?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) No 241/2014 - RTS for Own Funds requirements for institutions
  • ID: 2020_5615
  • Topic: Own funds
  • Date of submission:
  • Published as final Q&A: 24/02/2023

Validation rules between template F 18.01 and F 24.01

We have three groups of rules affected: A. There are these validations in template F 18.01 : Template ID columns Formula F 18.01 v7866_m (0010) {r0050} >= {r0070} + {r0080} F 18.01 v7867_m (0010) {r0050} >= {r0090} F 18.01 v7868_m (0010) {r0100} >= {r0110} F 18.01 v7869_m (0010) {r0100} >= {r0120} F 18.01 v8114_m (0010) {r0050} >= {r0060} F 18.01 v8115_m (0010) {r0060} >= {r0070} F 18.01 v8116_m (0020) {r0050} <= {r0060} F 18.01 v8117_m (0020) {r0060} <= {r0070} B. There are validations between these templates: ID Formula v8509_i {F 18.01, r0060, c0010}=={F 24.01, r0020, c0050} v8510_i {F 18.01, r0060, c0020}=={F 24.01, r0120, c0050} v8511_i {F 18.01, r0070, c0010}=={F 24.01, r0020, c0060} v8512_i {F 18.01, r0070, c0020}=={F 24.01, r0120, c0060} v8513_i {F 18.01, r0080, c0010}=={F 24.01, r0020, c0070} v8514_i {F 18.01, r0080, c0020}=={F 24.01, r0120, c0070} v8517_i {F 18.01, r0110, c0010}=={F 24.01, r0020, c0030} v8518_i {F 18.01, r0110, c0020}=={F 24.01, r0120, c0030} C. And this within template F 24.01: ID Template Formula v8051_m F 24.01 {r0320} = {r0010} + {r0020} + {r0120} Knowing that we have to comply with rule group A, rules B and C cannot be complied simultaneously. What set of rules should we follow, B or C?

  • 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: 2020_5613
  • Topic: Supervisory reporting - FINREP (incl. FB&NPE)
  • Date of submission:
  • Published as final Q&A: 10/09/2021

Reconciliation between the sum of Total Risk Exposure contributions in {C06.02;c250} and the Total Risk Exposure reported in ({C02.00;r010;c010}).

The sum of Total Risk Exposure contributions in {C06.02;c250} is not expected to differ greatly from the Total Risk Exposure reported in C02 ({C02.00;r010;c010}). However, the amount in the COREP C02 includes the RWA for entities consolidated using the equity method, while the amount in the COREP C06.02 does not, because entities consolidated using the equity method are out of the scope of this COREP. According to the reporting instructions, the entity should allocate the RWAs so that the value for the group is the sum of the values reported for each entity in ‘Group Solvency’ template. The entity consolidated using the equity method should play no role. I understand that the column 250 (and therefore columns 260 to 290) of the COREP C06.02 should not report actual risk figures, but “contributions”. According to the regulation 2014/680 Annex II paragraph 35, “The institutions shall define the most appropriate breakdown method between the entities to take into account the possible diversification effects for market risk and operational risk”. I understand that reporting entities has to split the total RWA for credit risk, market risk and operational risk (and other risks) – as reported in the COREP C02 – between entities reported in the COREP C06.02, using a breakdown method. Therefore, I understand that the “real” amount of RWA of entities consolidated using the equity method is in fine allocated to other entities. Hence, could you confirm that indeed, the amount of RWA of entities consolidated using the equity method should be allocated by the reporting entity to other entities using the “most appropriate breakdown method” in the COREP C06.02?

  • 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: 2020_5612
  • Topic: Supervisory reporting - COREP (incl. IP Losses)
  • Date of submission:
  • Published as final Q&A: 25/06/2021

Article 94 (4) discretion on Remuneration

Does the discretion of article 94(3) (a) provide the member states of the EU with the option to set the said threshold to the ultimate minimum (i.e. to set the threshold at zero)? And if the answer to the above question is yes, does the option not to transpose at all the wording of subparagraph (a) described above, effectively set the threshold at zero?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2020_5609
  • Topic: Remuneration
  • Date of submission:
  • Published as Rejected Q&A: 23/09/2022