To which vintage bucket under Article 47c CRR should the anniversary date of an exposure’s classification as non‑performing be assigned?

Based on the example provided by the submitter, an unsecured exposure is classified as non-performing on 31 March 2022 and it is still classified as such on 31 March 2025. Article 47c (2) of Regulation (EU) No 575/2013 (CRR) states that: ‘ For the purposes of point (a)(i) of paragraph 1, the following factors shall apply: (a) 0,35 for the unsecured part of a non-performing exposure to be applied during the period between the first and the last day of the third year following its classification as non-performing; (b) 1 for the unsecured part of a non-performing exposure to be applied as of the first day of the fourth year following its classification as non-performing’. Article 47c specifies the period to be considered for the application of the factors: “[...]between the first day [...] and the last day of the Xth year[...]”. In the example provided, the first day of the classification as non-performing is 31 March 2022 and the last day of the third year is 30 March 2025. This implies that 31 March 2025 should be considered as first day of the fourth year and, consequently in Commission implementing regulation (EU) 2024/3117- Annex I- templates C 35 on NPE loss coverage, this exposure would be reported in the time buckets > 3 years =< 4 years.