EBA · 2026_7807 Final Q&A

Clarification on validation v3078m under FINREP reporting

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
99
Topic
Supervisory reporting - FINREP (incl. FB&NPE)
Submitted by
Credit institution
Submitted
2026-03-31
Answered
2026-06-05

Question

In reference to the validation rule 'v3078_m' should the held for trading positions be excluded while reporting the maximum amount of the guarantee received in FINREP F_09.02

Background

Validation v3078_m compares the values in F_09.02 (r080, c010) with F_18.00.C (c205, c210, r330, r550). And, in F_18.00.C we are expected to report guarantees received on 'Debt Instruments other than held for trading or trading'. This means that guarantees received on held for trading exposure should not be reported in F_18.00.C. Since the validation rule is comparing F_09.02 with F_18.00.C, is it fair to assume that even while reporting the guarantee received in FINREP F_09.02, the guarantees received on held for trading exposure be excluded?

Answer

In Finrep template F 18.00 ‘Information on performing and non-performing exposures’, the financial guarantees received on 'debt Instruments held for trading or trading' are not reported. This does not imply that these financial guarantees received should also be excluded from the reporting in template F 09.02. The instructions to the latter (IT solutions – Annex V to Commission implementing regulation (EU) 2024/3117, Part 2, par 102 and 119) do not explicitly exclude the financial guarantees received on 'debt Instruments held for trading or trading' and the validation rule v3078_m compares the values in F_09.02 (r080, c010) with the ones F_18.00.C (c205, c210, r330, r550) but does not express an exact equivalence between them (xsum({F 18.00.c, (c0205, c0210, r0330, r0550)}) <= {F 09.02, r0080, c0010}). This rule will be satisfied even in case of existence of financial guarantees received on debt instruments held for trading or trading. For additional clarification regarding the “maximum amount of the guarantee that can be considered” under validation v3078_m in templates F 18.00.c and F 09.02, QA 2020_5634 should be taken into account.

Original source: European Banking Authority, Q&A ID 2026_7807

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.

Similar Q&As

More Q&As on this topic

📋 Track EU financial regulation continuously

Forseti monitors EU financial regulation and delivers personalised alerts anchored to verified official sources.

14-day free trial. No credit card required.