EBA ·

EBA extends non-recourse factoring past-due threshold to 90 days

EU credit institutions must apply a 90-day invoice threshold for non-recourse factoring

Change
EBA amended its Guidelines on the definition of default by extending the individual-invoice past-due treatment for non-recourse factoring from 30 days to 90 days.
Why it matters
The amendment changes how EU credit institutions classify individual invoices under non-recourse factoring for default purposes. Credit-risk, default-definition and regulatory-reporting teams must align past-due logic with the 90-day invoice threshold and CRR 3-aligned guideline updates.
Implications
  • Credit-risk teams at EU credit institutions must apply the 90-day individual-invoice past-due threshold for non-recourse factoring exposures.
  • Default-definition teams must remove 30-day invoice-level past-due treatment from non-recourse factoring classification logic.
  • Regulatory-reporting and prudential-model teams must align reporting controls and default-recognition settings with the amended EBA Guidelines.
Who is affected
  • Credit-risk teams at EU credit institutions
  • Default-definition teams at EU credit institutions
  • Regulatory-reporting and prudential-model teams
What to watch
  • Final Report publication date: May 7, 2026
  • 90-day individual-invoice past-due threshold for non-recourse factoring
  • Alignment with CRR 3 amendments

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