Line4

2 min readWarningEBA reporting framework 4.2Updated 10 November 2026

Commercial Real Estate loans to non-financial corporations (NFCs) other than SMEs) collateralised by immovable property cannot be less than the sum of three rows (EBA rule v7984_m)

A warning in the financial reporting return (FINREP 9), on template F 23.03, loans and advances collateralised by immovable property: Breakdown by LTV ratios.

Check your file against this ruleWhat to do if it fails

The rule in plain words

Commercial Real Estate loans to non-financial corporations (NFCs) other than SMEs) collateralised by immovable property cannot be less than these three added up:

  • Loans with a LTV higher than 60% and lower than or equal to 80%
  • Loans with a LTV higher than 80% and lower than or equal to 100%
  • Loans with a LTV higher than 100%

EBA checks it for ten columns, from gross carrying amount (0010) to exposures with forbearance measures (0110). That makes ten 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.

Gross carrying amount: Commercial Real Estate loans to non-financial corporations (NFCs) other than SMEs) collateralised by immovable property >= of which: Loans with a LTV higher than 60% and lower than or equal to 80% + of which: Loans with a LTV higher than 80% and lower than or equal to 100% + of which: Loans with a LTV higher than 100%

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 23.03 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 collateralised by immovable property: Breakdown by LTV ratios (F 23.03)

Rows

  • 0170Commercial Real Estate loans to non-financial corporations (NFCs) other than SMEs) collateralised by immovable property
  • 0180of which: Loans with a LTV higher than 60% and lower than or equal to 80%
  • 0190of which: Loans with a LTV higher than 80% and lower than or equal to 100%
  • 0200of which: Loans with a LTV higher than 100%

Columns

  • 0010Gross carrying amount
  • 0020of which: Exposures with forbearance measures
  • 0030Performing
  • 0050of 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

A worked example

The first of its checks, with simple numbers.

Illustrative values
Loans with a LTV higher than 60% and lower than or equal to 80%1,200
Loans with a LTV higher than 80% and lower than or equal to 100%800
Loans with a LTV higher than 100%450
Together2,450
What the rule then expects

Commercial Real Estate loans to non-financial corporations (NFCs) other than SMEs) collateralised by immovable property must then be at least 2,450.

2,450Passes
2,350Fails

A file that reports 2,450 passes. One that reports 2,350 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_23.03,r0170,c0010,} >= {F_23.03,r0180,c0010,} + {F_23.03,r0190,c0010,} + {F_23.03,r0200,c0010,}

The next five:

{F_23.03,r0170,c0020,} >= {F_23.03,r0180,c0020,} + {F_23.03,r0190,c0020,} + {F_23.03,r0200,c0020,}{F_23.03,r0170,c0070,} >= {F_23.03,r0180,c0070,} + {F_23.03,r0190,c0070,} + {F_23.03,r0200,c0070,}{F_23.03,r0170,c0090,} >= {F_23.03,r0180,c0090,} + {F_23.03,r0190,c0090,} + {F_23.03,r0200,c0090,}{F_23.03,r0170,c0050,} >= {F_23.03,r0180,c0050,} + {F_23.03,r0190,c0050,} + {F_23.03,r0200,c0050,}{F_23.03,r0170,c0110,} >= {F_23.03,r0180,c0110,} + {F_23.03,r0190,c0110,} + {F_23.03,r0200,c0110,}

And 4 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.