EBA Q&A · 2025_7637
Definition of Subordinated Debt holdings in Finrep vs COREP under CRR3
Rejectedfiled under Regulation (EU) 2024/3117 - ITS on supervisory reporting of institutionsSubmitted 28/11/2025 Rejected publishing date 11/02/2026
Question · verbatim
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 provided by the submitter · verbatim
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.
Rationale for rejection · verbatim
This Q&A has been rejected because answering it may pre-empt policy work currently in progress on Level 2 and 3.
Rejected questions have no answer.
Source: EBA Single Rulebook Q&A 2025_7637 · text as published, not rephrased · collected on 2026-10-08