2 min readWarningEBA reporting framework 4.2Updated 10 November 2026

Loans collateralised by commercial immovable property, non Performing: a lower-limit check across commercial Real Estate (CRE) loans and additional information on loans secured, and loans and advances collateralised (F 18.02.a, F 23.03, row 0040, EBA rule v903295_h)

A warning in the financial reporting return (FINREP 9), on templates F 18.02.a, commercial Real Estate (CRE) loans and additional information on loans secured by immovable property (I) and F 23.03, loans and advances collateralised by immovable property: Breakdown by LTV ratios.

The rule in plain words

For unlikely to pay that are not past due or past due <= 90 days: the absolute value of loans with LTV ratio higher than 60% and less than or equal to 80% cannot be less than the absolute value of loans with a LTV higher than 60% and lower than or equal to 80%.

The headline gives only the kind of check and the template, because the rule is too long to say in a headline. The plain words above say all of it.

How the Line4 Check report words itShow

Word for word as the report shows it when the rule fails.

the absolute value of F_18.02.A: Of which: Loans with LTV ratio higher than 60% and less than or equal to 80%, Unlikely to pay that are not past due or past due <= 90 days >= the absolute value of F_23.03: of which: Loans with a LTV higher than 60% and lower than or equal to 80%, Unlikely to pay that are not past due or past due <= 90 days

What to do if your filing fails it

  1. 01Open the templates 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 18.02 and 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

Commercial Real Estate (CRE) loans and additional information on loans secured by immovable property (I) (F 18.02.a)

Row

  • 0040Of which: Loans with LTV ratio higher than 60% and less than or equal to 80%

Column

  • 0090Unlikely to pay that are not past due or past due <= 90 days

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

Row

  • 0060of which: Loans with a LTV higher than 60% and lower than or equal to 80%

Column

  • 0080Unlikely to pay that are not past due or past due <= 90 days
Show the rule as writtenShow

EBA's formula. Cells are written as {template, row, column, sheet}.

abs({F_18.02.a,r0040,c0090,}) >= abs({F_23.03,r0060,c0080,})

Every FINREP 9 rule, by template

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