Yes, the contractually scheduled cash flow can be applied for determining M (the maturity) according to Article 162(2)(a) of Regulation (EU) No 575/2013 (CRR) where the obligor is not in the position to prolong the contract or to otherwise change the schedule in a way resulting in longer maturities.

A potential change to the schedule that would solely depend on a prolongation decision by the institution need not be taken into account when determining M. Were this required, the institution may have difficulty to applying a formula which is based on a fixed schedule. Where an institution is not in a position to calculate M as set out in Article 162(2)(a) of the CRR, it is instead required by Article 162(2)(f) to determine M as the maximum remaining time (in years) that the obligor is permitted to take to fully discharge its contractual obligations, where M shall be at least 1 year. Consequently, where the obligor is not in the position to prolong the time permitted to take to fully discharge its contractual obligations, the institution is still not required to use an M that is longer than according to the original schedule.

In conclusion, considering a longer maturity resulting from a prolongation by the institution instead of the original schedule is neither required by point (a), nor by point (f), of Article 162(2) of the CRR. This makes clear that a longer maturity that could result from potential changes to the schedule solely because of a prolongation decision by the institution need not be taken into account before the institution has made such a decision.

See further Q&A 2013 686.