FINREP – Loan commitments, financial guarantees and other commitments given

In the context of FINREP template F 09.01, could the EBA clarify whether the scope of columns 0100 and 0110 is intended to include exposures (commitments and certain contractual arrangements that are not commitments as referred to in CRR Article 5/110a/111(4)) that fall under CRR3 Annex I but are not recognised or disclosed under IFRS 9, IFRS 7 or IAS 37?

Under the revised Capital Requirements Regulation (CRR3), the definition of a commitment has been clarified to include any contractual arrangement offered by an institution and accepted by a client and it also introduced the concept of Contractual Agreements that are not commitments. This includes exposures that do not meet the definition of loan commitment under IFRS 9 (e.g. due to revocability) or that are outside of IAS 37 requirements (e.g. due to the absence of a present or possible obligation and contingencies being wholly within the issuer’s control). Despite not being recognised or disclosed for accounting purposes, such exposures may still be relevant for prudential reporting under CRR3 Annex I and the RTS EBA/RTS/2025/06 . We acknowledge the existence of EBA Q&A 2020_5495, however, it does not explicitly address commitments recognised under the prudential framework that are not recognised or disclosed under IFRS 9, IFRS 7 or IAS 37. EBA Q&A 2017_3478 raises a similar unanswered question.