EBA · 2025_7564 Rejected question

Treatment of Payment Institution and Electronic Money Institution safeguarding accounts in LCR C73.00 reporting

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
422, para. 5
Topic
Supervisory reporting - Liquidity (LCR, NSFR, AMM)
Submitted by
Credit institution
Submitted
2025-08-21
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Question

How should the safeguarding accounts of Payment Institutions (PIs) and Electronic Money Institutions (EMIs) be treated in the LCR C73.00 template? According to the legal requirements (e.g. PSD2 and EMD2), PI/EMI funds must be segregated from own funds and held separately in safeguarding accounts with credit institutions or invested in secure assets. It is unclear whether such safeguarded funds should be considered as deposits of financial institutions and therefore reported in row 230 of LCR C73.00, or whether they may be treated as other customer deposits and reported in row 240.

Background

The legal framework requires PIs/EMIs to safeguard client funds by holding them in segregated accounts, but the CRR and ITS on LCR reporting do not explicitly clarify the classification of these funds in C73.00. In particular, Commission Implementing Regulation (EU) 2021/451 (ITS on supervisory reporting), Annex XXIV – Liquidity Coverage – C73.00 template, defines rows 230 ("Deposits by financial customers") and 240 ("Deposits by other customers") but does not specify the treatment of safeguarded PI/EMI funds. Since these accounts are legally distinct from both PI/EMI own funds and ordinary customer deposits, further clarification is needed on whether they should be treated as financial institution deposits or other customer deposits in the LCR C73 reporting.
No answer published yet.

Original source: European Banking Authority, Q&A ID 2025_7564

This Q&A is published by European Banking Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

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