EBA · 2025_7637 Rejected question

Definition of Subordinated Debt holdings in Finrep vs COREP under CRR3

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
128
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Submitted by
Credit institution
Submitted
2025-11-28
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Question

Could you please confirm whether, following the implementation of Regulation (EU) 2024/1623 of the European Parliament and of the Council amending Regulation (EU) No 575/2013 (Capital Requirements Regulation 3 – CRR3), institutions will be required to report subordinated debt holdings differently in FINREP and COREP.

Background

Under Fin Rep the definition of subordinated assets includes any asset which is not highest in the order of priority. [Para 45 refers to a detailed definition in para 54: “Subordinated debt” instruments provide a subsidiary claim on the issuing institution that can only be exercised after all claims with a higher status have been satisfied”].   CRR3 introduces the concept of subordinated debt exposures under Article 128. This classification is prudential, based on eligibility for resolution/MREL purposes, and does not strictly follow legal ranking in insolvency. For example, a bond flagged as senior but treated as subordinated for CRR3 purposes would remain senior in FINREP unless its prospectus includes contractual subordination clauses.
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Original source: European Banking Authority, Q&A ID 2025_7637

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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