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2 min readWarningEBA reporting framework 4.2Updated 10 November 2026

Unlikely to pay that are not past due or past due <= 90 days cannot be less than exposures with forbearance measures (F 23.02, EBA rule v7937_m)

A warning in the financial reporting return (FINREP 9), on template F 23.02, loans and advances: additional information on gross carrying amounts.

Check your file against this ruleWhat to do if it fails

The rule in plain words

Unlikely to pay that are not past due or past due <= 90 days cannot be less than exposures with forbearance measures.

EBA checks it for 41 rows, from loans and advances (0010) to commercial Real Estate (CRE) loans to NFCs other than SMEs (0410). That makes 41 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.

of which: Non-financial corporations - SMEs, Unlikely to pay that are not past due or past due <= 90 days >= of which: Non-financial corporations - SMEs, of which: Exposures with forbearance measures

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 23.02 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: additional information on gross carrying amounts (F 23.02)

Rows

  • 0010Loans and advances
  • 0020of which: Households
  • 0030of which: Loans collateralised by residential immovable property
  • 0040of which: Non-financial corporations - SMEs
  • 0050of which: Commercial Real Estate (CRE) loans to SMEs
  • 0060of which: Non-financial corporations - other than SMEs
  • 0070of which: Commercial Real Estate (CRE) loans to NFCs other than SMEs
  • 0080Loans and advances at cost or at amortised cost
  • 0090of which: Households
  • 0100of which: Loans collateralised by residential immovable property
  • 0110of which: Non-financial corporations - SMEs
  • 0120of which: Commercial Real Estate (CRE) loans to SMEs
  • 0130of which: Non-financial corporations - other than SMEs
  • 0140of which: Commercial Real Estate (CRE) loans to NFCs other than SMEs
  • 0150Loans and advances in pre-litigation status
  • 0160of which: Households
  • 0170of which: Loans collateralised by residential immovable property
  • 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
  • 0220Loans and advances in litigation status
  • 0230of which: Households
  • 0240of which: Loans collateralised by residential immovable property
  • 0250of which: Non-financial corporations - SMEs
  • 0260of which: Commercial Real Estate (CRE) loans to SMEs
  • 0270of which: Non-financial corporations - other than SMEs
  • 0280of which: Commercial Real Estate (CRE) loans to NFCs other than SMEs
  • 0290Unsecured loans and advances without guarantees
  • 0300of which: Households
  • 0310of which: Non-financial corporations - SMEs
  • 0320of which: Commercial Real Estate (CRE) loans to SMEs
  • 0330of which: Non-financial corporations - other than SMEs
  • 0340of which: Commercial Real Estate (CRE) loans to NFCs other than SMEs
  • 0350Loans and advances with an accumulated coverage ratio > 90%
  • 0360of which: Households
  • 0370of which: Loans collateralised by residential immovable property
  • 0380of which: Non-financial corporations - SMEs
  • 0390of which: Commercial Real Estate (CRE) loans to SMEs
  • 0400of which: Non-financial corporations - other than SMEs

And 1 more.

Columns

  • 0080Unlikely to pay that are not past due or past due <= 90 days
  • 0090of which: Exposures with forbearance measures

A worked example

The first of its checks, with simple numbers.

Illustrative values
Unlikely to pay that are not past due or past due <= 90 days1,200
What the rule then expects

Exposures with forbearance measures can then be at most 1,200.

1,200Passes
1,300Fails

A file that reports 1,200 passes. One that reports 1,300 fails, by 100.

The numbers are illustrative, reported to the unit, so the rounding tolerance does not change the result.

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_23.02,r0110,c0080,} >= {F_23.02,r0110,c0090,}

The next five:

{F_23.02,r0400,c0080,} >= {F_23.02,r0400,c0090,}{F_23.02,r0370,c0080,} >= {F_23.02,r0370,c0090,}{F_23.02,r0230,c0080,} >= {F_23.02,r0230,c0090,}{F_23.02,r0080,c0080,} >= {F_23.02,r0080,c0090,}{F_23.02,r0240,c0080,} >= {F_23.02,r0240,c0090,}

And 35 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.