Line4

2 min readWarningEBA reporting framework 4.2Updated 10 November 2026

Loans and advances in litigation status: non-financial corporations, SMEs plus non-financial corporations, other than SMEs cannot be less than commercial Real Estate (CRE) loans to SMEs plus commercial Real Estate (CRE) loans to NFCs other than SMEs (F 23.01, EBA rule v7925_m)

A warning in the financial reporting return (FINREP 9), on template F 23.01, loans and advances: number of instruments.

Check your file against this ruleWhat to do if it fails

The rule in plain words

For loans and advances in litigation status: non-financial corporations - SMEs plus non-financial corporations - other than SMEs cannot be less than commercial Real Estate (CRE) loans to SMEs plus commercial Real Estate (CRE) loans to NFCs other than SMEs.

EBA checks it for 14 columns, from number of instruments (0010) to past due > 7 years (0170). That makes 14 checks. A failure names the one that failed.

How the Line4 Check report words itShow

The first of its checks, word for word as the report shows it when it fails. The others read the same, with their own column, row or sheet.

Unlikely to pay that are not past due or past due <= 90 days: of which: Non-financial corporations - SMEs + of which: Non-financial corporations - other than SMEs >= of which: Commercial Real Estate (CRE) loans to SMEs + of which: Commercial Real Estate (CRE) loans to NFCs other than SMEs

What to do if your filing fails it

  1. 01Open the template below and find the cells the rule reads.
  2. 02Compare the values in your file. If the first is smaller than it may be, one of them is wrong: check both before you change either.
  3. 03EBA allows a small rounding difference, worked out from the decimals each value is reported with.
  4. 04It runs only when your filing indicators mark F 23.01 as reported.
  5. 05This is a warning. It does not stop the filing on its own, but your authority may ask you to explain it.

The cells it reads

Loans and advances: number of instruments (F 23.01)

Rows

  • 0180of which: Non-financial corporations - SMEs
  • 0190of which: Commercial Real Estate (CRE) loans to SMEs
  • 0200of which: Non-financial corporations - other than SMEs
  • 0210of which: Commercial Real Estate (CRE) loans to NFCs other than SMEs

Columns

  • 0010Number of instruments
  • 0020of which: Exposures with forbearance measures
  • 0060Non Performing
  • 0070of which: Exposures with forbearance measures
  • 0080Unlikely to pay that are not past due or past due <= 90 days
  • 0090of which: Exposures with forbearance measures
  • 0100Past due > 90 days
  • 0110of which: Exposures with forbearance measures
  • 0120Past due > 90 days <= 180 days
  • 0130Past due > 180 days <= 1 year
  • 0140Past due > 1 years <= 2 years
  • 0150Past due > 2 years <= 5 years
  • 0160Past due > 5 years <= 7 years
  • 0170Past due > 7 years
Show the rule as writtenShow

EBA's formula, as written out for the first of its checks. Cells are written as {template, row, column, sheet}.

{F_23.01,r0180,c0080,} + {F_23.01,r0200,c0080,} >= {F_23.01,r0190,c0080,} + {F_23.01,r0210,c0080,}

The next five:

{F_23.01,r0180,c0130,} + {F_23.01,r0200,c0130,} >= {F_23.01,r0190,c0130,} + {F_23.01,r0210,c0130,}{F_23.01,r0180,c0020,} + {F_23.01,r0200,c0020,} >= {F_23.01,r0190,c0020,} + {F_23.01,r0210,c0020,}{F_23.01,r0180,c0070,} + {F_23.01,r0200,c0070,} >= {F_23.01,r0190,c0070,} + {F_23.01,r0210,c0070,}{F_23.01,r0180,c0150,} + {F_23.01,r0200,c0150,} >= {F_23.01,r0190,c0150,} + {F_23.01,r0210,c0150,}{F_23.01,r0180,c0060,} + {F_23.01,r0200,c0060,} >= {F_23.01,r0190,c0060,} + {F_23.01,r0210,c0060,}

And 8 more, the same formula for the other cells it covers.

Every FINREP 9 rule, by template

Checks like this one, run at the point of submission, are the first step to real-time supervision.