Country Comparison

14 countries · chapters I, II, III, IV, V shown · scroll sideways for more countries

Questions	Bulgaria	Croatia (Hrvatska)	Czechia	Denmark	France	Germany	Hungary	Ireland	Italy – ABI	Italy – ISP	Romania	Slovenia	Spain – AEV	Sweden
I. THE VALUATION
I.1 Regulatory Framework
a) Is there a legal framework in your Member State for the valuation of real estate for lending purposes (loan origination)? If yes: • Is this framework specifically for the valuation of real estate for lending purposes or are provisions enshrined in a broader piece of legislation? • Is it limited to the transposition of European or International Standards or is it broader in nature? • Please provide references and indicate whether it applies to both residential and commercial property. If there are differences between both property types, please explain.	In Bulgaria, the Bulgarian Valuation Standards (BVS) are mandatory under the National Valuation Act. These standards do not include specific requirements for valuations prepared for loan origination purposes. The BVS rely on certain aspects to the International Valuation Standards (IVS) and the European Valuation Standards (EVS). In practice, for loan origination, appraisers typically determine the market value of the property, and the definition of market value is provided within the Bulgarian Valuation Standards. The Bulgarian Valuation Standards (BVS) are not specifically tailored for valuations prepared for lending purposes. As mentioned above, the BVS provide definitions within a broader framework rather than detailed guidance for loan-related valuations. The BVS differ in certain aspects from the International Valuation Standards (IVS) and the European Valuation Standards (EVS). There is no distinction between RRE (Residential Real Estate) and CRE (Commercial Real Estate) in this context. According to the Bulgarian Valuation Standards (BVS), the applicable valuation approaches for both CRE and RRE are the Market Approach, Income Approach, and Cost Approach. These methods are applied based on the nature of the property, its location, and the independent judgment of the appraiser.	The legal framework for real estate valuation is regulated by the Law on Real Estate Valuation (Official Gazette 78/2015) and the Rules on Real Estate Valuation Methods (Official Gazette 105/2015). Previously mentioned Law on Real Estate Valuation and Rules on Real Estate Valuation Methods are specifically intended for the valuation of real estate, regardless of the purpose or reason for which the property is being valued. The legal framework does not provide for the use of European or International valuation standards. The legal framework applies to all types of real estate.	There is no specific “lex specialis” for valuation for lending purposes; general regulations and sectoral methodologies of banks are used. The fundamental legal anchor is Act No. 151/1997 Coll., on Property Valuation (which defines the “usual price” and methods) and related decrees; for banking practice, we rely on EVS/IVS and the Czech Banking Association Standard. Nevertheless, there are not universal, applicable and biding stadards of real estate valuation on level of legal framework.	The Danish Financial Supervisory Authority (DFSA) has issued detailed valuation standards specifically for the valuation of real estate for lending purposes in the Executive Order on Valuation of Mortgages and Loans in Real Property which are Provided as Collateral for the Issue of Covered Mortgage-Credit Bonds and Covered Bonds” (The Valuation Order) . The Order transposes and elaborates the European International Standards. The Order apply to all types of properties. and apply to both residential and commercial property and differs only for specific types of commercial property.	Yes, a legal framework exists. Articles L313-20 to L313-22 of the French Consumer Code Code de la consommation (Articles L313-20 to L313-22), within the legal framework of real estate credit (effective July 1, 2016), mandate that lenders must conduct and document a professional valuation of a property before issuing a mortgage loan offer to ensure borrower solvency.	Germany does not merely transpose EU standards but operates a broader and more detailed national framework, especially for mortgage lending value and covered bonds. A distinction must be made between more fundamental requirements for lending valuation, e.g. qualification and independence of valuers, documentation, etc., on the one hand, and specific methodological requirements within valuation approaches on the other. For the former, the following national requirements are relevant in addition to the European regulations: - Mortgage Credit Directive (2014/17/EU), transposed mainly via the German Civil Code (BGB) and supervisory practice - German Banking Act (Kreditwesengesetz – KWG) - Pfandbrief Act (Pfandbriefgesetz – PfandBG) - Minimum Requirements for Risk Management (MaRisk), issued by BaFin With regard to valuation approaches, the market value, mortgage lending value and property value are used in the banking industry's valuation process. There are numerous requirements for the mortgage lending value in the Regulation on the Determination of the Mortgage Lending Value (Beleihungswertermittlungsverordnung – BelWertV). This is an independent national valuation methodology that is not linked to international standards. There are various national regulatory requirements for market value. It is possible to use international standards. However, the main focus is on market value standardised in § 194 of the German Building Code (BauGB). Its structure corresponds to common international market value definitions. The Federal Valuation Ordinance (ImmoWertV) supplements § 194 BauGB with specific valuation rules for determining market value. However, it is only mandatory for the narrowly defined scope of application specified in the BauGB. While the guidelines on mortgage lending value refer exclusively to lending valuation, the regulations on market value determination are generally applicable guidelines that are used either in full or in part in lending valuation. In principle, the guidelines from all of the above are valid for residential and commercial properties. In terms of the details of the methods, there are some deviations for certain types of properties, e.g. owner-occupied residential properties.	The Hungarian property valuation activity in general is regulated by a decree issued by Misnistry of Finance (25/1997. (VIII. 1.) PM decree on the methodological principles for determining the collateral value of real estates.) The decree covers all the valuation processes including residential and non-residential (except agricultural lands) cases as well. (source (HUN): http://net.jogtar.hu/jr/gen/hjegy_doc.cgi?docid=99700025.PM ) Agricultural lands valuation should be done according to guidelines of decree issued by Ministry of Agriculture (54/1997. (VIII. 1.), what determines the framework of land valuations (including lands, fields, meadows, pastures, orchards, forests, fishing lakes and lakes) (source (HUN): http://net.jogtar.hu/jr/gen/hjegy_doc.cgi?docid=99700054.FM ) Additionally, all the Hungarian Mortgage Banks have to have their own inner regulation on determining collateral value, what must be approved by supervisory body (National Bank of Hungary). In addition there is a recommendation of the Hungarian National Bank (No. 18/2022 (XII.1.) on the management of real estate-related risks by financial institutions, which follows EU legislative changes and recommendations. The above mentioned regulatory instruments apply exclusively to property valuations conducted for credit institutions; however, they are frequently referenced when preparing Hungarian real estate valuations for other purposes. For business-oriented property valuations, these documents are regarded as the primary regulatory frameworks. The regulation itself does not refer to EVS or any other European standard. Compliance with international standards is a requirement imposed by banks, as stipulated in the relevant contracts. In addition, the Hungarian National Bank, acting as the supervisory authority, also expects adherence to these standards.	yes Article 19 of the Mortgage Credit Directive (MCD) was transposed into Irish law through the European Union (Consumer Mortgage Credit Agreements) Regulations. In practice, residential property valuations undertaken for mortgage lending purposes are generally required by lenders to be prepared in accordance with recognised professional valuation standards, principally the RICS Valuation Global Standards (Red Book) or the TEGoVA European Valuation Standards (Blue Book). For commercial property, there is no equivalent statutory valuation framework; however, regulated lenders generally require valuations to be undertaken by appropriately qualified valuers in accordance with recognised international or European valuation standards. The Irish framework is largely centred on the transposition of European requirements and the application of recognised international and European valuation standards, principally the RICS Red Book and TEGoVA Blue Book. Additional requirements are primarily delivered through lender policies and professional self-regulation rather than through a broader statutory valuation framework. The principal references are: European Union (Consumer Mortgage Credit Agreements) Regulations 2016, which transposed Article 19 of the Mortgage Credit Directive into Irish law for residential mortgage lending. RICS Valuation Global Standards (Red Book). TEGoVA European Valuation Standards (Blue Book). Relevant prudential requirements applicable to regulated lenders, including the Capital Requirements Regulation (CRR) and associated EBA guidance. Residential Property: The Mortgage Credit Directive requirements apply specifically to residential property used as security for mortgage lending. In practice, lenders require valuations to be undertaken by appropriately qualified valuers in accordance with recognised valuation standards such as the RICS Red Book or TEGoVA Blue Book. Commercial Property: There is no equivalent statutory framework specifically governing commercial property valuations for lending purposes. However, regulated lenders generally require commercial valuations to be prepared by suitably qualified and independent valuers in accordance with recognised professional valuation standards, principally the RICS Red Book or TEGoVA Blue Book. The key distinction is that residential mortgage valuations are supported by a specific legislative framework arising from the Mortgage Credit Directive, whereas commercial valuations are primarily governed through lender requirements, prudential regulation and professional self-regulation.	In addition to the Regulation (EU) No 575/2013 and the Regulation (UE) 2024/1623, in Italy, the valuation of real estate for lending purposes is regulated by: • Legislative Decree No. 72 of April 21, 2016, implementing Directive 2014/17/EU (Mortgage Credit Directive), which introduced, among other things, Article 120-duodecies (real estate valuation) into Legislative Decree No. 385 of September 30, 1993 (Consolidated Banking Act - TUB). This article requires the adoption of “reliable standards for the valuation of residential real-estate assets” when granting credit secured by a mortgage. https://www.bancaditalia.it/compiti/vigilanza/intermediari/Testo-Unico-Bancario.pdf • This article was implemented with the 17th update of Bank of Italy Circular No. 285 of December 17, 2013, which regulates, among other things: (i) the role of corporate bodies and corporate control functions in defining policies and processes for carrying out real estate valuation activities; (ii) requirements regarding the professionalism and independence of appraisers from the credit marketing process; (iii) outsourcing of real estate valuation activities to external appraisers; (iv) criteria for carrying out property valuations. https://www.bancaditalia.it/compiti/vigilanza/normativa/archivio-norme/circolari/c285/index.html The legal framework applies to both residential and commercial property.	In Italy there are not standards defined by law. There is a regulatory and normative framework that governs the valuation of real estate used as collateral in lending transactions, though the framework is a mix of statutory provisions, regulatory guidance and self-regulation: • Testo Unico Bancario (“TUB”, Legislative Decree No. 385/1993) o Article 120-duodecies TUB (which concerns consumer real-estate credit secured by mortgage) requires the adoption of “reliable standards for the valuation of residential real-estate assets” when granting credit secured by a mortgage. o More generally, the supervisory regulation by Banca d'Italia (through Circolari, e.g., Circolare 285) references valuations of collateral in order to implement the art 19 (1) of MCD regarding “reliable standard”. https://www.bancaditalia.it/compiti/vigilanza/intermediari/Testo-Unico-Bancario.pdf https://www.bancaditalia.it/compiti/vigilanza/normativa/archivio-norme/circolari/c285/aggiornamenti/Circ-285-Testo-integrale-al-50-aggto.pdf (pag 406) • “Guidelines for the valuation of properties as collateral for credit exposures” developed by the Associazione Bancaria Italiana (ABI), together with professional associations of valuers and banks https://www.abi.it/download/linee-guida-per-la-valutazione-degli-immobili-in-garanzia-delle-esposizioni-creditizie/ • Professional standards for valuers: the valuation profession (engineers, architects, surveyors) must align with national norms (e.g., UNI 11558) and international standards (e.g., International Valuation Standards – IVS; European Valuation Standards – EVS) when performing valuations for credit collateral purposes	In Romania, the valuation of real estate for lending purposes is regulated by national law and by the Central Bank’s regulations. These regulations apply for all types of real estate (land, residential, commercial properties, etc.). The laws that regulate the valuation profession are: Law no. 99/2013; Law no. 149/2013 and Law no. 221/2013.	No. The instructions from EBA are followed (EBA Guidelines on loan origination and monitoring EBA/GL/2020); there are no additional regulations from the Slovenian authorities.	Yes, Spain has a specific legal framework for the valuation of real estate for lending purposes. Valuations carried out for mortgage loan origination are governed by the Ministerial Order ECO/805/2003, which establishes the technical and methodological requirements for valuations of real estate assets used as collateral in credit operations. This Order also covers additional valuation purposes within its scope: Valuation of real estate assets for insurance and reinsurance entities, both for accounting purposes (fair value under the Accounting Plan approved by Royal Decree 1317/2008) and for compliance with solvency requirements established in Law 20/2015. Calculation of the real estate assets of real estate collective investment schemes, as regulated in the implementing regulation of Law 35/2003, approved by Royal Decree 1082/2012. Calculation of the real estate assets of pension funds, as regulated in the Pension Plans and Funds Regulation approved by Royal Decree 304/2004. While the regulation aligns with certain European principles (e.g., prudent valuation, transparency), it is broader in nature, incorporating national requirements that go beyond the mere transposition of European or international standards. The regulation applies to all types of real estate—residential, commercial, industrial, and other property categories—without distinction in its core requirements. However, for residential or commercial properties, specific documentation is required. For example, in the case of building elements other than dwellings or parking spaces, the valuation must include documents such as the community statutes, an equivalent document, or a certificate from the property manager indicating any usage restrictions or other circumstances that may affect value. For residential properties, additional checks are required regarding the public protection regime.	There is no specific regulation on valuation. However, if the loans are to be used as assets in the covered pool the collateral for the loans must have been valued in line with the rules in the Swedish regulation for covered bonds. There are other regulations to comply with such as EBA loan origination and monitoring and CRR, Basel 3.
b) If there is no specific legal framework, is the valuation of real estate for lending purposes covered by other means, e.g. self-regulation, sector recommendations or supervisory guidance?			Certification of Valuers: Real estate valuers must be certified by accredited certification authorities. These authorities ensure that valuers meet professional standards and qualifications. Regulated Trade: Real estate valuation is considered a regulated trade (“vázaná živnost”) under Czech law. To obtain the right to perform property valuations, a valuer must fulfill the requirements set by Act No. 455/1991 Coll., Trade and Business Licensing Act, (Živnostenský zákon).	N/A			We have legal framework. Financial institutions generally require compliance with international standards in relation to property valuations.	Valuation standards in Ireland are primarily governed through professional self-regulation. The two principal professional bodies are the Society of Chartered Surveyors Ireland (SCSI), in respect of RICS Red Book valuers, and the Institute of Professional Auctioneers and Valuers (IPAV), in respect of TEGoVA Blue Book valuers.			Not applicable.	Yes	N/A	Finance Sweden has developed two set of standards for valuation, one for commercial properties and one for owner-occupied residential properties. There are other organizations which handle authorisations of valuers, and which put together standards and guidelines for valuers.
c) Do national valuation standards exist? Is there any cross-reference to European and/or International Valuation Standards (EVS/IVS)?	Yes, please refer to the answers provided in section (a).	There is a national valuation standard in Croatia. It is regulated by the Law on Real Estate Valuation and Rules on Real Estate Valuation Methods.	In the banking sector, the Czech Banking Association (ČBA) Standard for the valuation of real estate is commonly used. This standard harmonizes procedures, requirements for independence, and the content of valuation reports. At the same time, it directly refers to the European Valuation Standards and the International Valuation Standards.	The Valuation Order transposes and elaborates the EBA guidelines and International standards but without any explicit references.	France relies on the Charte de l'Expertise en Évaluation Immobilière, which is the national reference cross-referenced with IVS and EVS. (La charte is signed by 16/17 associations, last version of 2025). The rules apply to residential property (and mixed residential/professional property where the borrower acts as a consumer) but do not apply to purely commercial real estate, which falls outside the scope of the Code de la consommation.	see a) There is no cross-reference to European and/or International Valuation Standards (EVS/IVS) in the national regulation. However, national valuation are broadly aligned with EVS and IVS but retain distinct national features.	There is no national valuation standard. However, the relevant provisions of international standards are reflected in the recommendations issued by the Hungarian National Bank.	Ireland does not maintain a separate national valuation standard. The two principal professional valuation frameworks used are the RICS Valuation Global Standards (Red Book) and the TEGoVA European Valuation Standards (Blue Book).			In Romania, valuation need to comply with ANEVAR valuation standards which incorporate the International Valuation Standards. In addition to IVS there are several local valuation standards which have been prepared in accordance with local legislation and practices – the most notable one being GEV 520 – valuation standard for loan security.	Slovenian Business-Financial Standard 2 – Valuation of Rights in Real Estate (SPS 2), that follows International Valuation Standards	Yes, Spain has national valuation standards. The ECO/805/2003 Order establishes comprehensive rules for the valuation of real estate assets, serving as the principal regulatory framework for mortgage valuations. These standards broadly align with the International Valuation Standards (IVS). In addition to this legal framework, the Asociación Española de Análisis de Valor (AEV) has developed a set of professional standards aimed at enhancing the quality, transparency, and consistency of valuation practices across the sector. These standards are adopted by AEV member valuation companies and are conceptually aligned with the International Valuation Standards (IVS). Among the most relevant AEV standards are the Sustainability Standard, which introduces environmental criteria into valuation processes; the Standard for Valuation of Properties Using AVMs, which regulates the responsible use of automated models with clear quality and traceability requirements; the Standard for Harmonization of Valuation Purposes; the Standard on Conditions and Disclaimers, which provides guidelines for the inclusion of technical and legal limitations in valuation reports; and the Standard for Measurement and Definition of Property Areas, which offers a precise methodology for quantifying and describing the surfaces of real estate assets.	The national standards that exist are private, see 1.1 (b). They do not refer to any international standards. Many valuers of commercial property are authorised by valuer organisations and must follow the requirements set by those organisations and members of estate agents organisations must apply the rules set by those organisations
d) How has the regulator in your Member State transposed Article 19(1) of the MCD regarding “reliable standards” for the valuation of residential property (into legislation or delivered through a professional body)? Indicate whether and how “reliable standards” are defined and whether and how the content of those standards are prescribed.	As stated above, under the National Valuation Act, the body responsible for setting the standards and regulating the valuation profession in Bulgaria is the Chamber of Independent Appraisers (CAIB). The Bulgarian Valuation Standards (BVS) are adopted by the CAIB and are mandatory for all real estate valuers.	The provisions of Article 19(1) of the MCD, which refer to “reliable standards“ for the valuation of residential property have been transposed into national legislation through the following acts: 1. Law on Real Estate Valuation (Official Gazette 78/2015) – which represents the fundamental legislative framework for carrying out real estate valuations in Croatia; 2. Rules on Real Estate Valuation Methods (Official Gazette 105/2015) – which sets out in detail the procedures, methods, and manner of preparing valuation reports; 3. Law on Residential Consumer Credit (Official Gazette 101/2017, 128/2022, 156/2023) – which transposes the MCD into national law, including provisions on the valuation of real estate used as collateral. The reliable standards are implemented through these legislative and regulatory acts, which define: • who is authorised to carry out valuations (certified valuers registered with the Ministry of Justice, Public Administration and Digital Transformation); • which valuation methods can be used (comparison, income, and cost approach); • the form and content of the valuation report (mandatory elements, documentation, data sources, valuation conclusion, valuer’s signature and seal); • the principles of objectivity, independence, and transparency in the valuation process. This ensures in practice that property valuations are conducted on the basis of reliable, consistent, and verifiable standards, in line with the European principles set out in Article 19 of the MCD.	Czech Banking Association (ČBA) Standard for the valuation of real estate Fundamental legal anchor is Act No. 151/1997 Coll., on Property Valuation+ Act No. 254/2019 Coll.+ Act No. 257/2016 Coll., on Consumer Credit	The DFSA has transposed the MCD in the Executive order on good practice for home credit: "When granting mortgage credit agreements, a mortgage creditor must apply reliable standards in the valuation of the real property underlying the mortgage credit agreement. In addition, the lender must ensure that reliable standards are applied when third parties perform the valuation on behalf of the lender. Reliable standards are the rules set out in section 2 of Executive order on valuation of mortgages and loans secured on real estate as collateral for issuance of covered bonds"	Monetary and Financial Code (Code monétaire et financier – CMF) for commercial lending Chapitre III : Les établissements de crédit spécialisés (Articles L513-1 à L513-33) - Légifrance For secured funding structures, Articles L513 2 to L513 7 CMF require that loans be adequately secured by real estate, which in practice necessitates robust property valuation, detailed further by ACPR regulations and instructions rather than by statute. Commercial real estate valuations for lending purposes in France are therefore driven by the CMF’s prudential framework, EU banking regulation (CRR/CRD), and ACPR supervisory guidance, rather than by explicit valuation rules set out directly in the CMF. Réglementation bancaire sur l’évaluation des biens immobiliers	No, the national implementation of the MCD in the German Civil Code (BGB) and the German Banking Act (KWG) does not specify what reliable standards are. Section 18a (7) of the German Banking Act (KWG) states the following: "(7) Credit institutions that grant consumer loans secured by real estate or by a real charge shall 1. use reliable standards when valuing the property and 2. ensure that internal and external valuers who carry out property valuations for them are professionally competent and sufficiently independent from the loan granting process to be able to carry out an objective valuation. [...]" However, Article 19(1) MCD (“reliable standards”) is effectively implemented through a combination of statutory requirements (BelWertV, PfandBG) and supervisory expectations under MaRisk. Reliability is ensured through methodological and documentation requirements.	Hungary implemented the MCD through amendments to its Act on Credit Institutions and Financial Enterprises and related ministerial decrees. Specifically, the Minister of Finance Decree 25/1997 (VIII.1.) on the methodological principles for determining the mortgage lending value of property was updated to align with the MCD. This decree sets out the rules for valuation methods used by credit institutions when granting mortgage loans. Hungarian law does not use the exact phrase “reliable standards,” but the concept is embedded in the requirement that valuations must be objective, independent, and based on market data.	The transposition of Article 19(1) was undertaken by the Irish Department of Finance, which concluded that the RICS Red Book and TEGoVA Blue Book are acceptable valuation standards. Instructions are issued to valuers who meet the criteria of the respective standards schemes. Both standards adopt the International Valuation Standards (IVS), produced by the International Valuation Standards Council (IVSC).	In Italy, the Italian Banking Association has established “guidelines for the evaluation of properties used as collateral for credit exposures”. These guidelines were developed in collaboration with the main national associations of expert valuers, as well as with the Royal Institution of Chartered Surveyors (RICS) and the European Group of Valuers’ Associations (TEGoVA). The guidelines are aligned with the EBA Loan Origination and Monitoring (LOM) approach, ensuring a standardised and reliable valuation process. The guidelines are used by banks and valuers. The Guidelines, referred to by the Bank of Italy itself in the regulatory impact analysis document accompanying the consultation process launched regarding the 17th update of Circular 285, are intended to respond to the principles set out in the current regulatory framework, in particular Article 120-duodecies of the TUB, which requires the adoption of "reliable standards for the valuation of real estate." They have been drawn up in the awareness that “to be considered reliable, valuation standards should take into account internationally recognised valuation standards” and in particular the most up-to-date versions of the IVSC’s International Valuation Standards, the European Valuation Standards, the RICS Valuation–Global Standards, and the Codice delle Valutazioni Immobiliari – Italian Property Valuation Standard Tecnoborsa Edition) in consideration of the national reality. abi.it/download/linee-guida-per-la-valutazione-degli-immobili-in-garanzia-delle-esposizioni-creditizie/?wpdmdl=29018&refresh=69174232958261763131954 In Italy there are also professional requirements for valuers: the valuation profession (engineers, architects, surveyors) must align with national norms (e.g., UNI 11558) and international standards (e.g., International Valuation Standards – IVS; European Valuation Standards – EVS) when performing valuations for credit collateral purposes.		The regulator in Romania has stated that valuations for loan security must be performed by individuals which have the qualification, abilities and experience required for performing a valuation. In addition to this, the valuation used by bank need to be compliant with IVS and ANEVAR Standards.	There is no MCD in Slovenia.	In Spain, Article 19(1) of Directive 2014/17/EU (Mortgage Credit Directive – MCD) has been transposed through Law 5/2019, of 15 March, regulating real estate credit agreements. Specifically, Article 13 of this Law requires that any property offered as collateral must undergo an appropriate valuation prior to the conclusion of the loan agreement. This valuation must be performed by a valuation company or service of a credit institution regulated under Royal Decree-law 24/2021, or a certified professional in accordance with Royal Decree 775/1997, and must be independent from the lender or credit intermediary. The valuation must be conducted using reliable and internationally recognized standards, as defined by Order ECO/805/2003, which prescribes the technical framework for property valuation in Spain. Order ECO/805/2003 serves as the operative definition of “reliable standards” in Spain. It provides a comprehensive and prescriptive framework that includes the application scope, core principles, valuation definitions, valuation methods, and formal reporting requirements. Mandatory for valuations carried out for regulated financial purposes, the Order is broadly aligned with the International Valuation Standards (IVS): a joint analysis conducted by the International Valuation Standards Council (IVSC) and the AEV – Asociación Española de Análisis de Valor, concluded that there are no major contradictions between the ECO Order and IVS. The Bank of Spain supervises valuation companies and ensures compliance with applicable standards and independence requirements. The Ministry of Economy is responsible for updating valuation regulations and, in accordance with the Tenth Additional Provision of Law 5/2019, it has recently amended Order ECO/805/2003 through Order ECM/599/2025, of 10 June, which entered into force in August 2025. This update incorporates advanced valuation typologies, including, among others, the principle of sustainability, the use of automated valuation models (AVMs), and the mandatory use of electronic signatures on valuation reports.	The government was of the opinion that the valuations already follow reliable standards so the directive’s requirements have simply been added to implementing law (SFS 2016:1024, Link: https://rkrattsbaser.gov.se/sfst?bet=2016:1024) and to the Swedish FSA’s regulation (FFFS 2016:29, Link: FFFS201629.pdf) as in the directive.
I.2 Valuation Bases & Methodology
a) What valuation bases (Market Value, Mortgage Lending Value, etc.) are typically used in your Member State for the valuation of property for lending purposes (please disregard at this stage the specific requirements of Art. 229 CRR considering that the Property Value is not an independent basis of value).	Market value is the primary basis of value applied in the lending process.	In the Republic of Croatia, the market value is used for the valuation of properties for lending purposes. The mortgage lending value is currently not formally defined or prescribed under Croatian legislation as a separate basis of value.	Market Value	Market value	Market Value (Valeur de Marché) is the primary basis. Mortgage Lending Value (Valeur Hypothécaire) is used, defined as a prudent value excluding speculative elements. But it does not replace the market value.	Market Value, Mortgage Lending Value	Market Value The market value is defined as the price which might be attained as of the date on which the valuation was processed, in the context of a business relationship and taking into account all legal facts, real qualities, other relationships and location of the real estate or another subject of the valuation, regardless of non-standard or personal relationships. Influences from exceptional circumstances of the market, personal relationships of the seller or of the purchaser or the influence of special popularity are not reflected in the market value. Extraordinary circumstances are deemed to be e.g. condition of distress of the seller or purchaser, or consequences of natural or other calamities. Personal relationships are understood to be, in particular, property relationships, family relationships or other personal relationships between the seller and purchaser. A special popularity is understood to be a special value attached to the property or service in light of the personal relationships to it. Market value is determined by a valuer making a prudent assessment of the property. Prudent assessment requires the following approaches: - Review of the future marketability of the property - Consider only the long term sustainable aspects of the property - Consider the normal and local market conditions - Highest and best use principal is not applicable (only the current use of the property may be considered) - Cost approach should be used as a control value only - If possible, all three valuation approaches should be applied (market, income and cost approach)* * In case of residential premises under 30million HUF, it is possible to determine and accept the value with the use of only one method (Market Comparison Method). Property professionals do not have information about the financial arrangements or about the borrower. Consequently, the valuer does not take into account the risks such as borrower risks, financial risks etc. Mortgage Lending Value The definition of MLV is written in a decree of Ministry of Finance 25/1997 for non-agricultural real estates and in the decree of Ministry of Agriculture 54/1997 for agricultural lands. In general the mortgage lending value may not exceed a usual price or market value of the real estate being assessed. The mortgage lending value is the property value gained via a careful assessment. During the calculation the specific risks originating from the long-term loans disbursed by mortgage banks and such features and yields of the property are taken into consideration that in the future any owner might face. When determining the mortgage lending value, in addition to the risks routinely analyzed, special attention must be paid to the following: - The risk of the long term stability of the value of the property; - The risk due to the unreliability of market value; - The risks due to the unreliability of other data; - the effects related to the enforcement of the claim (protection, sales costs, preservation). In order to mitigate the aforementioned risks: - a forecast should be prepared for the long term (at least for the loan period) regarding the market environment and the use and condition of the property; only those factors which are permanently valid may be taken into account; - Only the use of the property at the time may be taken into account and not the potential alternative use as result of a possible development, except for properties on building sites, which have not yet been constructed or completed; - If the circumstances refer to a right not registered in the land registry or an unrecorded fact, the situation must be clarified by contacting the related authority or examining the contract in case of a contract-based right; - In the interests of the reliability of the different market data, for all the applied market data including the sales-purchase comparison data, leasing data and building/construction costs at least 3 (5recommended) comparative sets of data should be provided and documented in a way that they can be accountable later; - 1All the data used in the valuation report must be identified in an accountable manner, and the accuracy of this data must be documented and assessed. Source: decree issued by Misnistry of Finance (25/1997. (VIII. 1.) PM decree) http://net.jogtar.hu/jr/gen/hjegy_doc.cgi?docid=99700025.PM	Market Value is the principal valuation basis used in Ireland for both residential and commercial property valuations undertaken for lending purposes. In practice, lenders generally require valuations to be prepared in accordance with recognised professional valuation standards, principally the RICS Valuation Global Standards (Red Book) or the TEGoVA European Valuation Standards (Blue Book), both of which adopt internationally recognised definitions of Market Value. Mortgage Lending Value is not used within the Irish market from a valuation perspective and is not a standard requirement for mortgage origination or secured lending valuations.	In Italy is generally used the Market Value	In Italy is typically used the Market Value. ISP apply the Prudential Market Value (PMV), see answer to point c)	In Romania, the valuation basis is represented by Market Value, as stated in the ANEVAR Standards.	Market Value, Liquidation Value	The basis of value used in Spain for the valuation of property for lending purposes is the Mortgage Lending Value.	Market value for lending purposes.
b) Based on what definition? Please provide the definition and reference to where it can be located.	definition - "Market Value is the estimated amount for which an asset should exchange on the date of valuation between a willing buyer and a willing seller in an arm’s length transaction, after proper marketing, wherein both parties acted knowledgeably, prudently and without compulsion." It is announced on the official website of the Chamber of Independent Appraisers in Bulgaria (CIAB) – www.ciab.bg – under the section for Bulgarian Valuation Standards (BVS).	The Market Value is used for the valuation of property, which is understood as the estimated amount at which a property could be exchanged as of the valuation date between a willing buyer and a willing seller, in a transaction according to market conditions, after appropriate advertising, wherein each party has acted in an informed and reasonable manner, without any compulsion.1	#VALUE!	The Danish Valuation Order states: "The institution's assessment of the value of the pledge must not exceed the reasonable cash market value of the property (market value) regardless of whether the property was sold at a higher amount. The reasonable cash market value of the property is defined as the estimated amount for which the property can be traded at the date of valuation by an independent transaction between an interested buyer and an interested seller under normal market conditions, each of which has acted on a well-informed basis, with caution and without compulsion. If the conditions are considered to make a special scarcity price, the institution must disregard this when measuring the valuation. The institution shall take into account when valuation to a current risk of changes in market conditions or structural changes. For valuation purposes, the institution shall include relevant comparable references.	see charter SL: Valeur venale = market value, based on International Valuation Standards 2024, RICS Valuation – Professional Standards 2025 (Red Book) and TEGOVA’s European Standards for Property Valuation 2025.	Mortgage Lending Value: Art. 16 (2) Pfandbrief Act: “The mortgage lending value must not exceed the value resulting from a prudent assessment of the future marketability of a property by taking into account the long-term sustainable aspects of the property, the normal regional market condition as well as the current and possible alternative uses. Speculative elements must not be taken into consideration. The mortgage lending value must not exceed a market value calculated in a transparent manner and in accordance with a recognized valuation method.” Market Value Art. 16 (2) Pfandbrief Act: “The market value is the estimated amount for which a property serving as collateral could exchange on the date of valuation between a willing buyer and a willing seller in an arm’s length transaction after proper marketing wherein the parties had each acted knowledgeably, prudently and without compulsion” Art. 194 Building Code: “The market value is determined by the price that could be achieved at the time of the valuation in normal business transactions, taking into account the legal circumstances and actual characteristics, other qualities and location of the property or other object being valued, without regard to unusual or personal circumstances.”	The market value of the property as defined in point 76 of Article 4(1) of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 648/2012.	Red Book - ‘Market Value’ définition is ; ‘the estimated amount for which an asset or liability should exchange on the valuation date between a willing buyer and a willing seller in an arm's length transaction after proper marketing, where the parties had each acted knowledgeably, prudently, and without compulsion’. Mortgage Lending Value - A definition is set out in the European Union Capital Requirements Regulation (CRR) Article 4(74): ‘The value of immovable property as determined by a prudent assessment of the future marketability of the property taking into account long-term sustainable aspects of the property, the normal and local market conditions, the current use and alternative appropriate uses of the property.’	We use the Market Value definition reported in Regulation 575/2013/EU and referred to in the “guidelines for the evaluation of properties used as collateral for credit exposures”.	Guidelines for the valuation of properties as collateral for credit exposures” developed by the Associazione Bancaria Italiana (ABI),	The definition of the Market Value is stated in the ANEVAR Standards and is the same as the definition in the International Valuation Standards.	IVS Effective 31 January 2025, IVS 102 Basis of Value. Market value is the estimated amount for which an asset and/or liability should exchange on the valuation date between a willing buyer and a willing seller in an arm’s-length transaction, after proper marketing and where the parties had each acted knowledgeably, prudently and without compulsion. Liquidation value is the amount that would be realised when an asset or group of assets are sold from a liquidation sale, with the seller being compelled to sell as of a specific date. Liquidation value can be determined under two different premises of value: (a) an orderly transaction with a typical marketing period, or (b) a forced transaction with a shortened market period. The valuer must disclose which premise of value is assumed	Mortgage Lending Value (individual property level): the value of a property as determined by a prudent valuation of its future marketability, taking into account the long-term sustainable aspects of the property, the normal regional market condition as well as the current and possible alternative uses. Potential speculative uses for the property at the date of the valuation are not considered. (Source: Article 4 — Definitions, ECO/805/2003 Order).	The definition of "market value" has become institutionalised by the International Valuation Standards Council ("IVSC") and the Royal Institution of Chartered Surveyors ("RICS"). For the IVSC “market value” means “the estimated amount for which a property should exchange on the date of valuation between a willing buyer and a willing seller in an arm’s length transaction after proper marketing wherein the parties had each acted knowledgeably, prudently and without compulsion. "The market value shall be documented in a transparent and clear manner". The IVSC make it clear that a “willing seller” in that context is simply a seller motivated to sell at the best price obtainable on the valuation date.
c) In case other valuation bases are used in your Member State for the valuation of property for lending purposes, please specify the effect, if any, on the final valuation.	N/A	Other valuation bases are not used in Croatia. Alternative valuation bases may be determined for specific purposes, but the lending (collateral) value is always derived from market value, and other bases have no effect on the final value used for lending decisions. From 01st July 2025. according to the CNB decision, all banks in Croatia for lending with purpose of buying real estate, lower value (market or sales value) has to be taken as base for LTV approval calculation.	#VALUE!	N/A		No further valuation bases. The valuation basis chosen directly affects the final valuation outcome, with Mortgage Lending Value generally resulting in lower, more stable values than Market Value.	Property valuations related to banks primarily focus on Market Value and Mortgage Lending Value. In exceptional cases - typically unrelated to lending purposes or not exclusively for that purpose - additional value types my be determined. These categories are also defined by the European Valuation Standards (EVS), such as Liquidation Value, Special Value, Technical Cost Value, Rental Value, etc. Such cases are rare and generally arise in response to specific client requests.	Alternative valuation bases are rarely used for lending purposes in Ireland. Market Value remains the dominant basis of value.		As far as ISP, the value is defined as Prudential Market Value i.e. prudent assessment of the future marketability of the property, taking into account long-term sustainable aspects of the property, the normal and local market conditions, the current use, and appropriate alternative uses of the property. Speculative elements should not be taken into account when estimating the prudential market value	For lending purposes, only the Market Value is used.	N/A	N/A
d) Depending on the valuation base used, which valuation approaches or methods (comparison, income, cost, etc.) are typically applied in your Member State to value properties for lending purposes in each category?	For residential real estate (RRE), the Market Approach is typically applied, while for commercial real estate (CRE), both the Market and Income Approaches are commonly used.	In the Republic of Croatia, all three main valuation approaches — comparison (market), income, and cost — are prescribed by national legislation and all are permitted, depending on the type and purpose of the property. Specifically: According to the Real Estate Valuation Act (Official Gazette 78/2015) and the related Regulations on Real Estate Valuation Methods, all three approaches are recognized and defined: The comparison approach is applied when sufficient comparable market transactions are available. The income approach is used for properties that generate income (e.g. commercial, rental, or investment properties). The cost approach is applied when there is insufficient market data or when valuing specific types of properties (e.g. special-purpose buildings). Therefore, all three valuation approaches are allowed and applied depending on the type of property, available data, and the purpose of the valuation, in accordance with Croatian legislation and professional valuation standards.	Approaches: comparison, cost - residential income, cost – commercial land valuation – residual methods based on comparison, income, cost Typical and preferable sub techniques: Direct comparison Income: direct capitalization (or term&revesion option), hospitality – DCF	The comparison method is used for private residential properties and agricul tural properties . According to the Valuation Order the valuation of most types of commercial properties (residential rental properties included), the investment value is used for lending purposes . The investment value is derived from the capitalisation of the net rentals . The basis for the calculation is primarily the actual rent or the market rent, depending on which is lowest, calculated on an annual basis . The depreciated replacement cost method can only be used for proper ties that are never or rarely sold in the market and, according to the DFSA guidelines, this method can only be used for very limited types of properties	Same approaches : comparison, income and cost	All three valuation methods (comparison, income, cost approach) are used in both market and mortgage lending value assessments. Owner-occupied residential property is generally valued using the cost value or comparative value. Properties where returns and income are the main focus are valued using the income approach. In addition to traditional commercial properties such as office, retail, hotel, logistics and social properties, this also includes multi-family houses.	a. Residential Properties: I. Comparison method II. Statistical-based valuation III. Investment/Income method IV. Depreciated replacement cost method b. Commercial Properties: I. Comparison method II. Depreciated replacement cost method III. Investment/Income method	The valuation approach adopted will depend on the nature of the property, the availability of market evidence and the valuation basis being applied. For lending purposes in Ireland, where Market Value is the predominant basis of value, the following approaches are commonly used: Sales Comparison Approach (Market Approach) Income Approach Residual Method Profits Method In practice, valuers will often use more than one approach as a cross-check, with the selection of the primary methodology determined by the property type, market evidence available and the requirements of the valuation instruction. For residential mortgage lending, the Sales Comparison Approach remains the most commonly adopted methodology, while commercial lending valuations frequently rely on the Income Approach supported by market evidence.	The applied methodology depends on the type of property and on the available data. Typically for residential real estate the comparison approach is used. For income producing property the financial method is used.	The applied methodology depends on the type of property and on the available data. Typically for residential RE the comparison approach is used. For income producing property the financial method is used	The main approaches used for lending purposes are the Market Approach and Income Approach. The Cost approach is mainly used as a secondary approach.	Comparable Transactions Method and Income approach are typically used in valuations for lending purposes, for assesment Market Value and Liquidation Value. Cost approach is used only in exceptional cases.	To calculate the Mortgage Lending Value of completed (not under construction) properties, the Adjusted Comparison method and the Income Capitalisation method are employed. In the Spanish regulatory context, the latter is typically applied through the updating of contractual or market rents over time. To calculate the Mortgage Lending Value of land or buildings subject to rehabilitation, the Adjusted Comparison method and the Residual (Static and Dynamic) method are employed. In the case of specialised properties with no clearly defined pool of buyers, the MLV is calculated using the Cost Method and the Income Capitalisation Method. To calculate the MLV of royalties, administrative concessions or leaseholds, the MLV is calculated using the Adjusted Comparison Method, the Inco+P15me Capitalisation Method and the Residual Valuation Method. Fully constructed properties: •Trade-Related Property: Adjusted Comparison method, Income Capitalisation method, and Cost method. The appraised value will be the lowest result obtained from the three methods. •Leased properties or those intended for rental (excluding dwellings): Income Capitalisation method based on market rents (or contractual rents if no market exists), and Adjusted Comparison method (adjusted for vacant possession where applicable). The appraised value will be the lowest result obtained from the two methods. •Leased dwellings: Income Capitalisation method* based on contractual rents, and Adjusted Comparison method (adjusted for vacant possession where applicable). The appraised value will be the lowest result obtained from the two methods. •Other properties: Adjusted Comparison method; if not applicable, then Income Capitalisation method* based on market rents; if still not applicable, then Cost method. Protected properties: •Dwellings and annexes: Value must not exceed the legally established maximum value. Properties under construction or rehabilitation: •General: Cost method. •Properties with suspended construction works: Cost method and Residual method. The appraised value will be the lowest result obtained from the two methods. Rural properties: •To determine land value: Adjusted Comparison method and Operating Income Update method. The appraised value will be the lowest result obtained from the two methods. Plots and land: •Urban or developable land: Adjusted Comparison method; if not applicable, then Residual method. •Non-sectorised developable land or non-developable land: Adjusted Comparison method and Operating Income Update method. *Applied, in the Spanish regulatory context, through the updating of contractual or market rents over time	Please refer to 1.2 (b). Private homes are commonly valued by using values of comparable houses. Multifamily houses and commercial properties are valued through capitalization and cash flow models.
I.3 Valuation Report: Form & Content
a) Does the legal or professional framework in your Member State specific to the valuation of properties provide minimum requirements in terms of the form and content of the valuation report? If yes, please indicate what these minimum requirements are.	YES. The Bulgarian Valuation Standards (BVS) state that the initial valuation must be prepared following a mandatory site inspection, and the valuation report must comply with the requirements set out in the BVS.	The minimum content is prescribed by Article 68 of the Rules on Real Estate Value Appraisal Methods. Reports must include details of the property, methodology, market analysis, calculations and a conclusion of value. Form and content of the valuation reports should contain the following: ■ A cover page with an identification number of the report, general data on the property being valued, (property type, address stated in the manner that unambiguously identifies the property), identity of the commissioning party with the exact address, the identity of the potential user (loan applicant/borrower) with the exact address, the identity of the valuer and the date the report is drawn up (month and year). ■ A brief statement specifying the most important assumptions or restrictions and a valuation statement in EUR, indicating the valuation date. ■ Specification of all persons responsible for preparing the valuation, certified by an authorized valuer and /or a person authorized to represent him/her. ■ Authorization of the valuer. ■ Important data: valuation date (day, month, year); date of on site visit; commissioning party – full name and address; property – type; property address – full address; data from the Land Registry Office; data from the Cadastral Office; property description – location, and condition, access to public road; existence of acts that prove the legality of the property or that would ensure its legality provided administrative procedures are carried out and detail of all possible restrictions on the property concerning its legality. ■ Statement of the property’s surface. ■ Analysis of market data necessary to calculate the value of property with the adopted method. ■ The calculation of property value with one of the methods (the second method can be an ancillary method, i.e. control of the stated value with a previous description of the method and the reason of its choice. ■ Photo evidence. ■ Documentation.	Minimum requirements in practice are set by the Czech Banking Association (ČBA) Standard (purpose, definition of the value basis, description of the property and the market, data/methods used, site inspection, valuation date, risk identification, appendices). The only legal framework is design pro specific Court Expert valuation reports bas on sub-legal Decree Nr. č. 503/2020 Sb.§ 39-51. These points are very specific and usable in banking environment only in limited extend. Outside of valuation for banking purposes: overall practice of real estate valuation reports in terms of content is indirectly inspired by IVSC/EVS/RICS standards are partly reflects.	There are no formal requirements in terms of the form of the valuation report, hence the form will differ between lenders . As for the content, the requirements are stated in the Valuation Order, section 29 . The terms under which the valuation has been carried out must be stated and justified, references to recent comparable sales/rents are mandatory and the reason for the assessment of the annual costs of property maintenance must be stated in the valuation.For commercial properties, the applied parameters for calculating the investment value must be documented e .g . it is mandatory to state the floor area and estimated market rent per square meter, respectively, for each of the categories of premises in the property . The same applies if possible for the actual rent per square meter	French legislation does not prescribe detailed statutory requirements for the form and content of valuation reports but the Charte de l'Expertise provides minimum requirements. Reports must include property identification, legal/town planning status, description, and detailed methodology.	• 5 (3) BelWertV sets out the content requirements for a valuation report. According to this, the valuer must address the following in the valuation report: - the quality of the property, - the location quality, - the regional property market, - the legal characteristics of the property, - the actual property characteristics, - eligibility for Pfandbrief coverage, - the usability, - the marketability and the - third-party usability. For the valuation, it is essential to obtain comprehensive information about the property being valued, i.e. information in particular about the technical and legal characteristics of the property and its location. In addition to the property documents, the findings from the property inspection are also a source of information. The regulatory requirements for lending valuation do not contain any explicit specifications as to which documents are necessary for a valuation. While some documents are essential for identifying the pledged property (Pfandidentität) and assessing the value of the mortgaged property, such as the cadastral map and an extract from the land register, a decision can be made on a case-by-case basis as to which additional documents are necessary. The key valuation parameters, data and assumptions must be presented and justified in a comprehensible manner in the valuation report.	The valuation report prepared for mortgage lending purposes should contain the following: - Naming of principal; - Subject of the valuation; - Identification of the property, the valued legal title; - The exact task of the valuer (determining the market value and mortgage lending value for bank loans); - Usage of the property (used by the owner, rented out, kept for investment purposes); - Valuation methodology or methodologies used and the related justification; - Proposed mortgage lending value based on the established market value; - Date of site visit and the date of preparation of the report; - The rights relating to the use of the valuation report (not to be provided…); - Documentation and identification of the sources of the data used; - The site visit and its date; - Author and the participants in compiling the material, and the proof of their professional certification; - The authenticated or electronic signature of the valuer to validate the established value; - Description of the property according to the land registry and in real terms, the description of construction authority provisions, building rules and their expected changes; - Geographical situation, demography, economy of the environment in which the property is located and the description of other important issues from the point of view of the valuation; - Description of the economic environment in which the property is located that determines the current use of the property, its value and the future possibilities; - Description of the real estate market situation, including factual data; - Description of the immediate environment in which the property is located, including the situation of the property in the settlement network and its situation within the settlement, its accessibility, public transport connections, infrastructure; - Description of the use of the property, including the past, present and future users, the way in which the property is used, the intensity of use and the related financial consequences; - Description of the land, including the size, shape, relief, greenery, available public utilities, the extent to which it has been built on, the proportion of the land that can be built on, the buildings and features; - Description of the buildings, applying the “from far to close” principle, a detailed description of the primary and secondary building structures, and a description of their condition; - Definition of the applied measures to ensure comparability (areas: gross, net, useful…); - Protection of the property (either monumental or natural protection); - In the valuation report the presumptions must be listed based on which the valuation is valid. The steps and calculations of the valuation must be described in detail, in a straightforward and verifiable manner in the valuation report. The valuation report must be supported by annexes. - Copy of the authenticated title deed not older than 90 days before determining the mortgage lending value in accordance with the *national and banking provisions; - Copy of the original land registry map and an extract of the regulation plan if this is necessary for the identification of the property or for the valuation procedure; - Technical documentation and architectural drawings of the property. - Photos of the property, inside and outside - Contracts and other documents that are relevant to understand the legal situation of the property, including documents about mortgages; - Any other fact or data considered during the valuation Supporting documents for the compilation and verification of the external Valuation In particular the following supporting documents are required: - Copy of cadastral map from the Real Estate Register - Extract(s) from the Real Estate Register relating to any and all relevant units, buildings and lands (including co-owned properties), not older than 3 months - Purchase contract/acquisition title - Demolition decision / zone decision / construction permit / use permit decision / permit for change of use - Construction plans – sections, designs, views - Technical report / real estate description - Declaration of individual ownership (in case of an apartment ownership-structure) - Construction contract, including annexes / time schedule / cost budget - Lease Contract(s) / survey of rents. - Contracts for the establishment of the rights corresponding to easements - Contracts for the establishment of pre-emptive right	There is no statutory format prescribed in Irish legislation for valuation reports prepared for lending purposes. However, recognised professional valuation standards establish minimum requirements regarding the form and content of valuation reports. In practice, lenders also frequently require valuers to complete institution-specific reporting templates for mortgage origination and secured lending purposes. For valuers operating under the RICS Valuation Global Standards (Red Book), the valuation report must contain sufficient information to enable the client to understand the valuation opinion and the basis upon which it has been prepared.	The "Guidelines for the Valuation of Properties Used as Collateral for Credit Exposures" establish that the form, content, and length of the valuation report are at the discretion of the bank, corporate or association entities, or the valuers, provided they comply with the guidelines themselves, without prejudice to legal requirements. Specifically, the guidelines, which refer, among others, to the EBA LOM, establish that the valuation report must contain the following minimum information: • Identification of the parties: Client (person who ordered the valuation); valuer (name, surname, register/order, qualification); Party requesting the loan. • Date: Date of inspection Date of valuation. Date of valuation report • Inspection: Verification of property characteristics, consistency, state of maintenance, , environmental factors, easements, and rental status. • Property Identification: Location and Description and Access • Ownership and Easements: Notary Deed or Appropriate Document; Verification of Active/Passive Easements • Building and Urban Planning Legitimacy • Estimated Value with Indication of Valuation Method • Limitations and Assumptions • Declaration: Compliance with Guidelines	Please refer to the “Guidelines for the valuation of properties as collateral for credit exposures” developed by the Associazione Bancaria Italiana (ABI) pag 30	The legal and professional framework in Romania specifies the minimum requirements for the content of the valuation reports. These requirements are in line with the IVS requirements (IVS 106).	Slovenian Business-Financial Standard 2 – Valuation of Rights in Real Estate (SPS 2: Ocenjevanje vrednosti pravic na nepremičninah (Uradni list RS 48/18, 13. 7. 2018, veljavnost 1. 9. 2018 in 7/25) ) Minimum Requirements for a Valuation Report under SPS 2_ Each written valuation report must be prepared in accordance with IVS and SPS 2, according to minimum requirements defined in SPS 2 must include the following: 1. Identification and Description Clear identification and description of the property or property rights being valued. 2. Purpose and Scope Statement of the purpose of the valuation and the reason for conducting it. Description of the scope of the valuation process. 3. Valuation Basis Specification of the basis of value (e.g., market value, liquidation value), including the source of the definition. 4. Dates Date of property inspection, valuation date, and report preparation date. 5. Data Collection and Verification Description of the extent and method of data collection, verification, and reporting. 6. Assumptions and Limitations Clear and accurate description of any assumptions or special assumptions that directly affect the valuation. Statement of uncertainties related to the valuation, if applicable. 7. Analysis and Methodology Presentation of all data, information, and valuation methods used. Justification of analyses, opinions, and conclusions. Explanation of any exclusion of standard valuation methods. 8. Highest and Best Use Analysis of the highest and best use of the property, unless not applicable (in which case, justification must be provided). 9. Legal and Regulatory Context Consideration of legal restrictions, third-party rights, leases, and planning regulations affecting the property. 10. Valuer’s Statement Signed statement by the valuer, confirming compliance with SPS 2. 11. Client’s Declaration Declaration by the client regarding the accuracy of provided data, or explanation if such a declaration is not included. 12. Restrictions Clear statement of any limitations on the use, distribution, or publication of the valuation report. 13. Transparency Assurance that no critical information has been omitted or concealed. 14. Deviation Explanation Explanation of any deviations from SPS 2 provisions, including causes and consequences.	Yes, Order ECO 805/2003 dedicates Articles 61 to 78 provide a detailed description of the minimum requirements in terms of the form and content of the valuation report (Elaboration of the valuation report and the valuation certificate). The report must include, at a minimum, the following sections: -Applicant and purpose of the valuation -Identification and location of the property -Checks carried out and documentation consulted -Description of the locality and surroundings -Description and surface area of the land -Description and surface area of the building -Urban planning status -Legal regime regarding protection, tenure, and occupancy -Market analysis -Data and calculation of technical values -Final valuation figures -Conditions and warnings -Additional observations -Date of issuance, expiry, and signatures -Annexed documentation -Index at the beginning of the report indicating the page number of each section and annexed document	No legal requirements are specified. The professional framework of the valuer organisation “Samhällsbyggarna” has a rather general framework, with general principles such as independence of the valuer, and some formal requirements on the valuations. The latter is rather basic, such as name of property, date of valuation and so on. There is a general recommendation to follow the standards set by Finance Sweden (see 1.3.c). These standards are more detailed.
b) Should the form and content of valuation reports be prescribed, are there differences between residential and non-residential properties? Please describe as appropriate.	NO - ther are not difference between RRE and CRE valuation reports	The content of valuation for lending purposes is strictly prescribed by regulator. Residential and commercial reports share the same structure, differing mainly in analytical depth.	For commercial assets, a more detailed market/income analysis is expected (lease agreements, CAPEX, VAC, LTA), while for residential properties, the emphasis is on comparable samples and the local market. (Practice according to ČBA/EVS.) AVM are used only for residential properties based on individual and internal guidelines of individual banking institutions.	N/A	Yes, differences exist in practice even though the Charte de l’expertise immobilière imposes a common core structure: residential valuation reports are generally shorter and more standardised, rely mainly on the sales comparison approach, include a simplified market analysis, and are often produced using lender specific templates derived from the Charte. By contrast, non residential (commercial) valuation reports are more detailed and analytical, typically rely on income based approaches (capitalisation and/or DCF), include extensive market and lease analysis with risk and sensitivity assessments, which the Charte explicitly allows by applying a principle of proportionality between asset complexity and depth of analysis. Because French law does not set fixed rules for valuation reports, practice is mainly shaped by professional standards.	In practice, valuation reports for commercial properties are more extensive and detailed than for residential properties due to higher complexity and risk. Where not explicitly prescribed by law, professional standards and lender requirements define typical report content. If a loan can be classified as a small loan within the meaning of § 24 BelWertV and the requirements for the mortgaged property are met, the following relief can be claimed: Instead of a formal valuation report in accordance with § 5 BelWertV, a so-called simplified valuation is sufficient. Extensive textual explanations, e.g. on the assessment of the location quality or the condition of the property, can be omitted and are replaced by standardised text modules and/or assessments based on a selection from predefined scales. Regardless of this, the value-relevant approaches must be justified, albeit in a simplified form.	The content of valuation for lending purposes is strictly prescribed by regulator and mortgage banks as well.	The RICS Red Book does not prescribe the wording of valuation reports, but it sets out the minimum information that must be included in both the report and the terms of engagement with the client. There are notable differences between residential and non-residential valuation reports. Residential mortgage valuations are generally more standardised, with reports often completed using lender-specific templates and relying primarily on comparable sales evidence. Non-residential (commercial) valuation reports are typically more detailed and may include analysis of occupational leases, rental income, yields, cash flows, development potential, market trends, ESG/sustainability considerations and asset-specific risks. Commercial reports frequently require the application of multiple valuation methodologies and a more extensive explanation of assumptions, inputs and professional judgement.	The form and the content (minimum information) is the same for residential and non-residential but the applied valuation methodology is different.	The bank has established specific form and content of the evaluation report. The scheme is the same for residential and non-residential but of course the content and the applied methodology are different	There is no differentiation between the types of properties. All valuation reports must comply with IVS 106 for all real estate.	For reporting purposes in secured lending, especially for residential properties it is usefull tu use prescibed form for the wider use and collateral data entering. So in Slovenia used form known as Povzetek ZBS (ZBS Summary Form) serves only as a summary of the essential findings from the report and forms an inseparate whole together with the full report, which we see appropriate.	There are no significant differences in the required content between valuation reports for residential and non-residential properties. The same minimum sections must be included in both cases, although certain sections may differ to reflect specific characteristics depending on the type of property being valued	There are two standards set by Finance Sweden (see 1.1.b)
c) If the form or content of the valuation report are not prescribed, what form does the valuation report typically take? Please specify differences between residential and commercial property valuation reports.	N/A	The content of valuation report is strictly prescribed by regulator.	See above. The main difference is not about identifying of the subject of the valuation but about the income characteristic, providing broader market evidence, broad argumentation, providing clear calculation with transparent formulas, more detail appendixes.	N/A				Where the form and content of valuation reports are not prescribed by legislation, the typical practice in Ireland is for reports to be prepared in accordance with recognised professional valuation standards, principally the RICS Valuation Global Standards (Red Book) or the TEGoVA European Valuation Standards (Blue Book). For residential mortgage lending, valuation reports are commonly completed using standardised templates provided by individual lenders. These reports typically focus on property identification, inspection findings, market evidence, key assumptions, material risks and the final opinion of Market Value. Commercial property valuation reports are generally more detailed. They typically include comprehensive analysis of the property, tenure, occupational arrangements, rental income, market conditions, valuation methodology, assumptions, ESG/sustainability considerations, risk factors and supporting evidence underpinning the valuation conclusion.		The minimum content is the same for residential and non-residential, what is different is the valuation methodology applied	Not applicable.	For reporting purposes in secured lending, Slovenia uses a summary form of the real estate valuation report for secured lending, known as the ZBS Summary Form. The ZBS Summary Form is not regulatory prescribed. This form represents a condensed version of the full valuation report and enables a simpler and clearer overview of the key information contained in the report. Under no circumstances does the summary replace the preparation of the full valuation report, which must be prepared in accordance with the International Valuation Standards. Instead, it serves only as a summary of the essential findings from the report and forms an inseparable whole together with the full report. For the purpose it is used, as a summary of key data, especially for collataral data entering, we do not see key differencies in residential and commercial properties.	N/A	Finance Sweden has developed standards cover the following areas: definition of the task, background information, presumptions for the object and a judgement of the Market Value.
I.4 Technology & Valuation
a) Does the legal or professional framework in your Member State provide specific rules/guidance on the use of digital valuation tools (AVMs, Artificial Intelligence etc.)? If yes, what does this consist of and is it restricted to a particular type of property? Please specify whether there is a correlation with the requirements of Article 208(3a) CRR and of section 7.4 of GLOAM or whether the latter provisions are of stand-alone application in your Member State.	NO. For initial valuations, AVMs and other automated models are prohibited. The initial valuation must be prepared individually by the appraiser, based on a mandatory site inspection, relevant documentation, and the methodology outlined in the Bulgarian Valuation Standards (BVS).	The legal and professional framework currently does not contain specific rules or guidance explicitly regulating the use of digital valuation tools (AVMs or AI) for property valuation in lending purposes. The Law on Real Estate Valuation (Official Gazette 78/2015) and the Rules on Real Estate Valuation Methods define the methodology, procedures, and content of valuations, but do not specifically address digital or automated methods. In practice, AVM tools are used as a supplementary aid – for example, for internal checks or indicative analyses – however, the final valuation must be carried out by a certified valuer, in accordance with the law and professional standards.	There are no direct Czech “AVM regulations”; the Czech National Bank (CNB) and banks apply the EBA Guidelines on Loan Origination & Monitoring (LOM). These guidelines allow statistical/AVM methods for monitoring and identifying the need for revaluation; for initial valuation, the emphasis is on a qualified valuer and local inspection. CNB as regulator is not explicitly against using AVM but highlights prudential approach for using. AVM are not seen as solution but only as tool.	Mortgage banks can only use AVMs for loan origination if they get approval from the DFSA . Most Danish mortgage banks have received approval to use own models for private residential properties but the precise basis of the mortgage banks’ application and the authorisation given have not been published .	In France, there is no specific legal framework nor dedicated section of the Charte de l’expertise immobilière that formally regulates the use of AVMs, AI, or fully automated valuation tools for lending purposes as substitutes for expert valuations. Digital valuation tools are therefore not regulated as such, and their use is mainly addressed indirectly through prudential banking regulation (Code monétaire et financier, CRR/CRD); supervisory expectations of the ACPR; and professional principles of reliability, independence, and accountability set out in the Charte.	AVMs are primarily applied to residential properties. Commercial property valuation remains largely valuer-driven. Art. 19 (2) BelWertV provides rules on the use of statistical approaches: “(2) Notwithstanding par. 1 sentence 2, in the case of single-family and semi-detached houses as well as of condominiums, the comparative value may also be determined using computer-assisted database-supported valuation models if their suitability and the underlying data comprehensibly derived on the basis of suitable statistical models are validated at least annually by a qualified body independent of the system provider and database provider. The valuation results must also be reviewed by the Pfandbrief bank at regular intervals within the scope of quality assurance; § 24 par. 2 sentence 3 shall apply accordingly with the proviso that, in the case of lendings on single-family and semi-detached houses, the cost approach is to be used for the review. The samples must, in particular, also be representative according to the type and regional location of the properties.” The regulations are viewed as being on top of the regulations at European level from the CRR and EBA GL LOAM and apply explicitly to the determination of mortgage lending values.	It is possible to use AVM. The legal and regulatory references are the follows: Ministry of Finance Decree 25/1997 (5th appendix) and the bank's internal regulations.	Ireland does not appear to have separate domestic legislation prescribing a comprehensive, property-specific regime for the use of automated valuation models, artificial intelligence or other digital valuation tools. Their use is principally governed through: directly applicable EU prudential requirements, particularly the Capital Requirements Regulation; the EBA Guidelines on Loan Origination and Monitoring, as applied by supervised credit institutions; and the professional standards followed by qualified valuers, principally the RICS Red Book Global Standards incorporating the International Valuation Standards.	The "Guidelines for the Valuation of Properties Used as Collateral for Credit Exposures” are aligned with the EBA Loan Origination and Monitoring (LOM) approach, ensuring a standardised and reliable valuation process. Notably, the guidelines also encompass the use of Automated Valuation Models (AVMs), providing a framework for their application in property valuations. This inclusion reflects the growing role of AVMs in the valuation process, offering a balance between traditional valuation methods and modern technological advancements.	Please refers to the “Guidelines for the valuation of properties as collateral for credit exposures” developed by the Associazione Bancaria Italiana (ABI) pag 21. So far the AVMs are not so reliable as such are used but only back test for internal checks.	The ANEVAR valuation standards have specific rules for AVMs and they state that these tools can be used only for properties which have a large enough population that can safely provide accurate results. These tools are mainly used for residential properties and for agricultural lands.	Professional framework: Slovenian Business-Financial Standard 9 – "Property valuation for secured lending based on prudent and conservative valuation criteria" (SPS 9: Ocenjevanje vrednosti nepremičnin za zavarovano posojanje na podlagi preudarno konservativnih meril ocenjevanja vrednosti (Uradni list RS, št. 7/25) ). SPS 9 includes minimum requirements on the use of AVMs tools: "The valuation must not be merely an automated calculation performed by an Automated Valuation Model (AVM). This requirement does not exclude the possibility of using an AVM as a tool to assist a qualified valuer who possesses the necessary qualifications, skills, and experience to carry out valuations for secured lending purposes. When AVMs are used as an auxiliary tool, valuers must exercise due professional care and comply with IVS provisions, disclosing any deviations where applicable. For valuations where AVMs have been used as a tool, valuers bear full professional and financial responsibility. Valuers are obliged to disclose the use of AVMs in the report. No model without the professional judgment of a valuer, such as an Automated Valuation Model (AVM), can perform a valuation that is compliant with IVS.". AVMs tools are more commonly accepted for residential properties due to data availability and model reliability. There is no stand alone application in Slovenia .	Yes, the Bank of Spain, which oversees the banking sector, issues “Circulares” on the use of AVMs which are binding on banks and on Valuation Firms: -In the Circular 4/2017, the Bank of Spain sets out those cases where financial institutions are allowed to use AVMs to value specific parts of their portfolios. -In 2019, the Bank of Spain published a Supervisory Guideline for the use of AVMs by appraisal companies, which sets out best practices and technical requirements for AVM use, including the need for robust and traceable methodologies, calibration and documentation of the models and quality control through sampling and backtesting. According to this guideline, AVMs should be used exclusively for properties with a certain degree of homogeneity—that is, assets with repeatable characteristics located in active transaction markets, where sufficient comparable data is available. The recent amendment to Order ECO/805/2003, effective August 12, 2025, introduces Article 15 bis, which regulates the use of AVMs for valuations carried out under Royal Decree-Law 24/2021, in any case, it is important to emphasize that AVMs are strictly prohibited for use in mortgage origination. The general framework of this new article draws directly from the abovementioned Bank of Spain’s 2019 Supervisory Guideline. The Bank of Spain is expected to issue a new Circular to further detail the requirements for AVM-based valuations. In addition, the AEV has issued an AVM`s Standard Guide for professional valuation firms to follow and comply.	No, there are no specific rules regarding digital valuation tools. AVMs are typically only used for private homes. Banks have internal rules on when and where to use such tools.
b) For what purpose are digital tools and/or AI employed in your Member State? - Mortgage origination, monitoring and review of property values, revaluation etc. - Capital requirements, covered bond funding, securitisation transactions, mortgage portfolio risk management etc.	N/A		Portfolio monitoring, ongoing revaluation, and risk flagging; less frequently for origination without inspection (typically only for low-risk, standardized residential real estate – manly in bigger cities)	AVMs can be used for all the mentioned purposes		All of the purposes mentioned in the question are possible; the breadth of the area of application varies from bank to bank.	Any of the listed issues can be helped or done by digital tools.	For mortgage origination, the role of automated tools is more constrained because the institution and valuer must ensure that the valuation is fit for its lending purpose and based upon sufficiently reliable property-specific information. An AVM-generated estimate may form part of the process, but for example, under the Red Book, it does not become a compliant valuation unless a valuer applies professional judgement. Furthermore, all valuations produced under the RICS Red Book must identify and state the status of the responsible valuer. Restrictions on inspection, investigation or information must be agreed, documented and reported, and the instruction must be declined if the limitations prevent a professionally adequate valuation. For monitoring and revaluation, Article 208 (3a) CRR expressly permits advanced statistical or mathematical methods to monitor property values and identify properties requiring revaluation, subject to the prescribed controls. Accordingly, automation is particularly suited to portfolio-level monitoring and exception identification rather than being treated automatically as a substitute for an individual valuation	Currently, in general,banks do not use artificial intelligence in the credit granting process or in the real estate valuation process. In some cases: - digital tools are used to collect documentation for appraisals; the process of assigning and managing a property appraisal is conducted through an IT workflow, with appraisals drafted and delivered in digital format. - an AVM tool is purchased from a third-party vendor to analyze and evaluate the accuracy of the property values expressed by appraisal firms in the Individuals' origination appraisals. The analysis is performed semi-annually and includes all individual origination appraisals.	As far as one knows there are not specific purposes; currently ISP do not apply AI applications in the credit granting process; digital tools are used to collect documentation for the valuation of the appraisers; the process of assigning and managing a real estate valuation is carried out through an IT workflow, with appraisals drawn up and delivered in digital format.	Digital tools are mainly used for monitoring and reviews of property values, mainly used for residential properties and for agricultural lands.	Mortgage origination, monitoring and review of property values, revaluation etc.: using an AVM as a tool to assist a qualified valuer to carry out valuations for secured lending purposes	AVM & AI are not allowed for use in Mortgage Origination. Circular 4/2017 of the Bank of Spain, que entró en vigor el 1 de enero de 2018, regulates the frequency and methodology with which valuations for accounting purposes must be carried out by financial entities, came into effect. Its objective is to monitor and mitigate credit risk associated with mortgage products, and it obliges the annual revaluation of assets securing non-performing loans, loans under special monitoring (Stage 2), and assets allocated to financial institutions. Moreover, it obliges banking entities to pay attention to any possible market drops, in which case they must also revalue the guarantees of all loans in normal and sub-standard situations. The Circular allows valuations of these types of assets to be carried out using AVM methodologies whenever their values are below 250.000 € and they can be considered “susceptible to repeated production” (e.g.housing units, garages or storage rooms). The Circular allows valuations of these types of assets to be carried out using AVM methodologies only in very specific situations, depending on the credit risk classification, the type of property, the amount of the transaction, and either the length of time in the risk category or the time held on the balance sheet in the case of foreclosed assets. In all cases, the assets must be considered “susceptible to repeated production” (e.g. housing units, garages or storage rooms), and the valuation must follow generally accepted valuation practices.	Digital tools are used for both purposes.
c) Scope of digitisation: Please determine the scope of automated and digitised tools in your Member State. Are they confined to data collection, do they deliver reliable property values or are they even used to produce full or partial valuation reports including description of locations, infrastructure, building characteristics etc.? If the latter is the case, is internal data used or it is permitted to purchase data from an external data provider?	Currently, the Member State does not collect data from valuation reports and does not provide any aggregated information related to market development, real estate prices, or other relevant indicators.		AVMs used in the Czech Republic provide full-fledged valuations based on comparisons with completed transactions. The source of these transactions is data from the Land Registry, complemented by comparisons with currently listed properties.	As the AVM applications of the Danish mortgage banksand the authorisation given have not been published it is not possible to give general answers.	In France, the scope of digitisation is generally limited.	Subject to European regulations stipulating that the valuer is responsible for the valuation result, the tools provide proposals for valuation results. In addition, some tool providers also offer text modules for specific content of the valuation report that can be accessed. With regard to these textual explanations, there is currently a great deal of momentum, particularly with regard to the use of AI tools. Both, internal and external data is permitted.	AVMs can be used for mass mass or portfolio evaluations and with certain restrictions for loaning activities as well. Starting from November 2021, AVMs may also be prepared for first time valuations of the property set defined in Decree No. 25/1997 of the Ministry of Finance, in accordance with Recommendation No. 15/2021 of the Hungarian National Bank and the internal guidelines stipulated in OTP’s internal regulations. Statistical valuation can be applied if the property to be appraised: - is an apartment (not a family house or other type of real estate), - the floor area is maximum 150 m2 - is located in capital or its agglomeration, or in the country's major cities, - and is located in a settlement where at least 10 properties were sold in the last 1 year, and the registered purchase prices differ by no more than 30%. The requested loan amount and the encumbrances already registered on the property together cannot exceed 60% of the property's estimated value (mortgage lending value). This methodology cannot be used for ongoing constructions, only for completed properties!	The scope of digitisation in Ireland extends beyond basic data collection. Digital tools may support: retrieval and verification of property and market information; analysis of transactions, rents, yields and indices; geospatial and locational analysis; property matching and comparable selection; statistical estimation of value; portfolio monitoring and identification of outliers; automated calculations and report population; and drafting or assembling parts of valuation documentation. Nevertheless, there is an important distinction between an automated output and a professional valuation. The Red Book defines a valuation model as a quantitative implementation of a method that converts inputs into outputs used in developing a value.	With respect to the Performance Evaluation Process of Appraisal Companies in the individual residential sector, some banks adopt AVM for backtesting purposes by using data and property values produced by a third-party provider. Those data and values are not used to produce appraisal reports or other reports. In other cases, the real estate valuation is entrusted to external data provider.	Currently digitisation is mainly limited to data collection; in the next year BIM for creating digital models and technologies (i.e. drones and 3d scanning) could improve data availability and consequently the activity of the appraiser	Currently, the main purpose of digitalisation is data collection regarding property details. This data is also being used for the creation of AVMs / other statistical tools.	In Slovenia, automated and digitised tools in property valuation are primarily used for data collection from public records. Examples of such providers include Arvio d.o.o. and Caris d.o.o. (tool Valuer). These tools assist valuers by aggregating market data, transaction records, and property characteristics.	Certain stages of the valuation process, such as reading and interpreting documentation, have undergone significant digital transformation. In recent years, tools for data processing and syntactic analysis—such as parsers—have been developed to extract key information from property registry documents or data from external sources like the cadastral registry. AI is currently playing a role in these processes by transforming administrative tasks, streamlining workflows, and improving operational efficiency. Virtual assistants and chatbots are increasingly used to facilitate communication between clients, valuation firms, and banks. AI also supports operational tasks such as automated assignment of valuation tasks, monitoring and automated generation of budgets, reports, and invoices; and assistance in drafting valuation reports through automated text generation. In Spain, mortgage lending requires a full individual valuation in accordance with Order ECO/805/2003, which mandates an interior inspection and a signed report by a qualified technician affiliated with a valuation company authorized by the Bank of Spain. As a result, the scope for AI in the actual valuation process is limited. AI can only act as a support tool for the appraiser. AI may also assist the valuation firm in tasks such as error detection, comparable property search, predictive market analysis, and the integration of sustainability criteria. There is significant adoption of digital and automated tools—particularly AVMs—in the accounting valuation of properties held as collateral or repossessed assets. However, the Bank of Spain has set clear limitations on their use, as detailed in its supervisory guidance (see response 1.4.a).	Automated and digitised tools provide both point estimates and an estimate of the reliability of the point estimate. If the reliability is good enough the point estimate can be used as a basis for valuation. Automated and digitised tools can use data for other providers than the bank, for example the transaction price for all houses are publicly available and of course used in such models.
d) Quality requirements: How are the reliability of the tools and their outputs assessed, e.g. by controlling the inputs, back-testing, supervision and/or plausibility checks by valuers etc.?	N/A		Model risk management (input control, backtesting, independent validation), plausibility checks by a valuer; banks have internal guidelines.	The banks follow in line with paragraph 210 in the EBA guidelines the precribed a plausibility check by the valuer before a model value is applied.	The Charte de l’expertise immobilière remains clear that the valuer is responsible for the final opinion of value, which limits the use of automated outputs without human review.	In addition to the requirements of Article 208(3a) CRR and EBA GL LOAM, please refer to the answer to question 1.4. a) in the context of mortgage lending value.	In banking operations mostly AVM results are examined afterwards by checking the values in a normal way. AVM is considered pretty accurate if it is based on an appropriate database.	Professional scepticism is important. The Red Book therefore requires the valuer to apply professional scepticism, take reasonable steps to verify the information relied upon, maintain an adequate audit trail and record inputs, calculations, investigations, analyses, assumptions, professional judgements and quality-control procedures. The ultimate control is the responsible valuer. Each Red Book valuation must be prepared by, or under the supervision of, a named appropriately qualified valuer who accepts responsibility for it.	In some cases, based on the report produced by the third-party provider that classifies the appraisals as "valid," "plausible," and "critical," banks carry out manual in-depth analyses of the appraisals classified as "critical" by the bank's internal appraisers. In other cases, the appraisal reports are first subjected to the providers' internal quality controls, which meet specific certifications. Then, banks review the appraisals by relying on a third-party appraisal firm.		The reliability of the tools is going through a quality review, mainly by checking the input data and also the output supplied by the tools. This output is also verified and back-tested by a qualified valuer.	When AVMs are used, they serve only as supporting tools for qualified valuers who apply professional judgment, valuers remain fully responsible for the valuation outcome and must disclose the use of AVMs in their reports.	According to the Bank of Spain’s Supervisory Guide for the Use of AVMs, the reliability of AVM outputs must be assessed through robust validation procedures. Section 2.7 of the guide mandates the implementation of backtesting, requiring valuation companies to perform a statistically significant sample of full individual valuations among the properties assessed via AVMs. Valuation companies must apply a solid, regular, and properly validated methodology that rigorously estimates current property prices in their respective local markets. To ensure estimation accuracy, AVM results must be contrasted with actual market transactions or full individual valuations conducted within the twelve months prior to the AVM-based valuation, using comparable assets in terms of location, size, construction, and other relevant characteristics. Valuation companies must apply prior data cleansing procedures, including criteria for detecting and correcting errors, missing information, and outliers. Techniques such as winsorizing or trimming are used to treat extreme values and ensure data consistency. Before accepting an AVM valuation assignment, firms are expected to verify the sufficiency of available property data—such as cadastral identifiers, postal codes, built and usable areas, terraces, bedrooms, garages, storage units, age, condition, year of last renovation, protection status, and geolocation coordinates. Annex 4 of the guide outlines the quantitative metrics required to evaluate AVM reliability. These include the Mean Absolute Percentage Error (MAPE), which measures the average percentage deviation between AVM estimates and benchmark values; the Root Mean Squared Error (RMSE), which reflects the magnitude of absolute errors; and the Coefficient of Dispersion (COD), which assesses the variability of valuation results relative to the median ratio. In addition, the AEV’s Standard for the Valuation of Real Estate Using Automated Valuation Models (AVMs) establishes a rigorous backtesting procedure to ensure model reliability.	The tools are back-tested against transaction prices. Individual banks can also do additional quality controls, but those differs between banks.
e) Do you foresee an increase in the use of automation and digitisation of property valuation processes in the future? Please describe potential technological developments which could impact the valuation profession and accelerate its transformation, notably through the use of AI.	N/A	An increase in the use of automation and digitalisation in property valuation processes is expected in the coming period, particularly through the development and application of AI and AVMs. Several important technological trends are anticipated that could significantly impact the valuation profession and accelerate its transformation, including: • The development of advanced AVM systems • The application of artificial intelligence and machine learning • The digitalisation of data collection and verification processes (e.g. automatic retrieval of data from registries, land registry books, and market databases).	In my opinion, there is great potential in the use of AI for property valuation, and I see significant opportunities especially in the valuation of commercial real estate. However, at present, it remains an auxiliary tool that “for now” cannot replace a valuer. For example, AI has not yet conducted an inspection or measured properties itself	Due to model improvements, including use of AI, it is likely that a larger portion of valuations than present will be done using AVMs	Increasing use of AI for data scraping and predictive "Green Premium" modeling is expected by 2030.	Continuous development is taking place, particularly in the use of AI for creating the descriptive parts of the report, data research and extracting valuation-relevant information from official documents.	The future of the real estate valuation profession locally and in a wider range also will be shaped by the rapid advancement of data science and geospatial technologies, the integration of AI-driven solutions into our processes, the evolution of drone and laser technologies, and increasingly efficient communication.	Valuers may spend less time on manual data assembly and repetitive report drafting, and more time on instructing and challenging models, verifying source data, interpreting outputs, investigating exceptions, assessing property-specific risks and explaining conclusions to clients and regulators.	AI can be increasingly used in the appraisal field to gather increasingly timely information on the asset being valued, even pre-compiling the appraisal report and leaving the appraiser solely responsible for the on-site inspection and verification of the resulting congruence Furthermore, with the widespread and intensive use of the AVM methodology, it will be necessary to analyze large volumes of data with AI to obtain more accurate and faster estimates. Finally, with the introduction of Property Value, which is the long-term value of the property, the analysis of historical and current data will allow for greater confidence in future price trends.	Due to the current regulations of the Italian market, we do not see a potential increase of the A.I in a short time. The contribution of the automation and A.I, in this phase, could be supportive to the quality checks and to the appraiser along the valuation process.	We can safely state that we foresee an increase in the level of digitalisation and the use of Ais in the valuation field, mainly for monitoring purposes (in the near future with the possibility to extend the usage outside just monitoring) and it is heavily dependant on the access to databases with accurate and relevant information. The benefit for increasing the use of Ais in the valuation process is the reduction in processing times for the loan origination process.	Yes, a significant increase in automation and digitalization of property valuation processes is expected, particularly for simpler properties (mainly residential) in more liquid markets where sufficient data is available for models and assessments. Digitalization will also enable better integration of available data from public and proprietary databases, improved data validation, partially automated report preparation, and a reduction in human errors. In the initial phase, we expect the implementation of tools designed to assist appraisers, such as automated collection and validation of available data, data analysis, pre-preparation of property reports, and models capable of performing value checks and supporting portfolio value monitoring. Large Slovenian companies that appraise a high volume of properties already have valuation processes that are largely automated. Expected technological advancements include: • Advanced Automated Valuation Models (AVMs) – initially for quality control and pre-preparation of valuation opinions. • Computer Vision – for analyzing photos, satellite imagery, property access, and legal status from land registries, enabling monitoring of property changes. • Integration of ESG Criteria – where AI evaluates energy efficiency and sustainability parameters based on public data and predefined benchmarks. • Generative AI for Report Preparation – reducing administrative workload and speeding up the processing of loan applications. Large Slovenian companies that appraise a high volume of properties already have valuation processes supported with AI tools.	Looking ahead, several Spanish valuation firms—particularly those with greater technological development—are closely monitoring improvements in AVM models, economic indices, drone technology, smart homes equipped with cameras, and artificial intelligence.	Yes, it will increase depending on the need of portfolio valuation and the future development of digital lending products.
I.5 ESG, climate risk, transformation risk
a) How are ESG factors and climate risk taken into consideration in the valuation process? Do Market Values and/or Mortgage Lending Values reflect the ESG characteristics of properties?	The CIAB has launched specific guidance for valuers regarding ESG factors, particularly Energy Performance Certificates (EPC), and their impact on market value.	ESG factors and climate risks are currently not formally incorporated into the legal framework governing real estate valuation. The Law on Real Estate Valuation and the related Rules on Real Estate Valuation Methods do not prescribe any obligation for separate assessment of ESG aspects. Elements of ESG factors are taken into consideration through market analysis and the technical characteristics of properties, such as: • energy efficiency and possession of an energy performance certificate, • use of sustainable materials and construction technologies, • location-related factors associated with climate and environmental risks (floods, seismic activity, fire, drought, etc.). In real life, the market value reflects ESG characteristics to the extent that the market recognizes and values them through higher demand and prices for “green” or energy-efficient properties.2	Energy performance (EPC/PENB according to Act No. 406/2000 Coll.) and the costs of achieving standards (renovation) are reflected in income, CAPEX, and market demand, which in turn affect MV.	ESG factors including energy consumption and climate risks are considered to the extent the market particiåpants in the local market attach importance to it as it can be seen in the comparable sales prices and rents for properties with and without the ESG factors present/partly present	ESG factors and climate risks are taken into account in valuation in line with the principles of the Charte de l’expertise immobilière, as applied by AFREXIM. AFREXIM explicitly recognises that the ESG performance of real estate assets increasingly influences transaction prices, rents, liquidity, and investor demand, and therefore may be reflected in Market Value when supported by market evidence, while the valuer remains an observer and analyst of the market and not a normative judge of sustainability performance. AFREXIM has developed ESG rating grids (already operational for offices and shopping centres) that rely on objective, weighted criteria (such as energy performance, carbon trajectory, climate risks and regulatory compliance) allowing valuers to compare assets and analyse correlations between ESG scores and transaction prices, with the declared objective of progressively modelling their impact on values. Following the Charte de l’expertise immobilière, the valuer remains fully responsible for interpreting ESG and climate data and for determining whether, and to what extent, these factors are reflected in the final opinion of Market Value.	ESG factors are already taken into account in both market value and mortgage lending value, although S and G risks play a subordinate role because, in terms of banking supervision and regulation, they primarily address the corporate level rather than the property level. The prerequisite is that the E-factors are relevant to value. In addition – especially for risks that are not relevant to value – the valuer can act as an information provider for other areas of the bank, such as risk management. The established definitions for market and mortgage lending values offer sufficient leeway and guidelines for taking into account transitional risks as the energy efficiency of buildings as well as location-based physical climate-related and environmental risks. For further details see chapter 4.3. of the following publication: https://www.pfandbrief.de/wp-content/uploads/2025/07/Consideration-of-environmental-risks-in-property-valuation_vdp_7_July_2025.pdf	The classification of real estate assets from an ESG (Environmental, Social, and Governance) perspective requires a comprehensive evaluation of multiple factors. Energy performance certifications, specialized classifications, and other analyses, solutions serve as essential references in this process. These sources provide objective benchmarks that support informed decision-making and ensure alignment with sustainability standards and regulatory requirements.	The Red Book identifies a range of potentially relevant ESG considerations, including: Energy efficiency and energy ratings. Carbon emissions and decarbonisation requirements. Flood, heat, drought and other physical climate risks. Building adaptability and resilience. Biodiversity and environmental constraints. Building safety and governance-related risks. However, valuers are required to distinguish between ESG factors that are demonstrably reflected in market behaviour and those that are not.	The "Guidelines for the Valuation of Properties Used as Collateral for Credit Exposures" in a specific appendix provide a series of insights that can be useful for the valuer as a starting point for evaluating the degree of energy efficiency and "safety" of the properties in the estimation of their market value. With specific reference to the practices used by banks, in some cases, ESG factors and climate risk are internalized in the appraisal, and banks require the appraiser to take them into account when calculating the asset's value. In the presence of high physical risk, when assessing the credit, some banks prudentially reduces the maximum LTV ratio allowed by bank regulations, for example, by a minimum of 5%. In other cases, currently, physical risks are simply detected, but not used for property valuation purposes.	In principle Market Values and Mortgage Lending Values could include and discount (partially or totally) the effects of the ESG factors; applying the property values the appraiser should be mitigate the risk of any double counting, estimating the potential contributions of the ESG factors affecting the Market Value and the Property Value.	The ESG factors and climate risks which influence the market value of a property are being accounted for in the Market Value supplied by the valuers.	Valuers follow IVS and EBA guidelines, property characteristics, elements such as energy efficiency, building certifications and compliance with environmental regulations are assessed where relevant. Climate Risk Assessment: Exposure to flood zones, landslides, or other climate-related hazards is considered. Market Values may reflect ESG characteristics indirectly, as sustainable properties often achieve higher market demand and pricing	As of August 12, 2025, a modification to Orden ECO/805/2003 enters into force, introducing the Principle of Sustainability. Under this principle, property valuation methods must consider, where applicable, indicators reflecting the impact of environmental factors on the value of the asset. In applying this principle, environmental and climate-related risks that may affect the property will be taken into account. In general, Market Value implicitly reflect the Environmental characteristics of properties, although not always in a disaggregated or explicit manner. -Territorial scale: Environmental risks such as desertification or temperature rise tend to affect entire municipalities or regions uniformly. These risks are therefore embedded in local real estate market dynamics rather than being attributed to individual assets. -Property-specific level: Features like energy efficiency were traditionally captured through the assessment of construction quality, which influences both market perception and valuation outcomes. For example, better insulation, modern HVAC systems, and sustainable materials contribute to higher ratings in the building’s technical appraisal, indirectly reflecting ESG performance. Regarding the Social and Governance aspects of ESG, these are systemic characteristics that tend to affect the real estate market as a whole, rather than individual properties. Dimensions such as institutional stability, regulatory quality, and social cohesion shape investor confidence, market transparency, and long-term demand across entire regions or countries. In addition, the AEV has issued a Sustainability`s Standard Guide for professional valuation firms to follow and comply.	Adjustments for ESG factors and climate risk is determined by the valuer on a single property by property basis when relevant. By construction ESG factors and climate risks that are reflected in the input data from comparable sales information is included in the value.
b) Are there rules in your Member State requiring assessment of EU Taxonomy alignment of a property in the valuation report and the subsequent impact of compliance/non-compliance on property values?	NO	Rules requiring an assessment of a property's compliance with the EU Taxonomy in the valuation report, or any obligation to reflect the impact of compliance/non-compliance on the assessed value, are currently not formally mandatory.	Property valuations typically include an ESG assessment or an Energy Performance Certificate (EPC/PENB). Some banks automatically integrate this data into their internal valuation tools.	No	Reports increasingly include EU Taxonomy alignment, especially for institutional commercial lending	There is currently no explicit legal obligation to assess EU Taxonomy alignment within valuation reports. However, supervisory expectations e.g. under MaRisk require banks to consider ESG risks in collateral valuation.	No, Hungary does not currently require valuers to assess EU Taxonomy alignment or its impact on property values in official valuation reports. However, ESG and Taxonomy compliance are becoming significant in financing and investment decisions, which indirectly influences valuation practice. Future regulatory developments under CSRD may increase demand for such assessments, but formal valuation standards have not yet incorporated them. Banks and investors may request sustainability data or certifications. There are also institutes what use their own calculation models on determining ESG related factors that can affect a property and its value.	At present, there is no specific Irish valuation standard mandating that valuers must provide a formal EU Taxonomy alignment assessment for every property valuation.	No	Ther are not specific requirements in the ABI Guidelines for the assessment of the EU taxonomy alignment of a property in the valuation report of the appraiser; however, ISP has foreseen the assessment of the EU Taxonomy alignment in the credit granting process.	These aspects are part of the risk assessment departments of the banks and is related to the overall appraisal of the client and the company activity and not just the collaterals.	When assessing the value of a property, valuers must, in accordance with valuation standards, take into account all characteristics of the property, which includes ESG factors and climate-related risks where relevant. Elements such as energy efficiency, building certifications, and compliance with environmental regulations are considered as part of the valuation process. There are no specific national rules.	The reform of Order ECO/805/2003, effective from 12 August 2025, introduces the Principle of Sustainability, requiring valuers to consider environmental and climate-related indicators when relevant to the asset’s value. However, there is currently no regulatory obligation to assess EU-Taxonomy alignment or to quantify its financial impact on valuations, although some valuation firms have already begun to incorporate such assessments voluntarily. In this context, the AEV – Asociación Española de Análisis de Valor has published a Sustainability Standard, approved on 23 July 2025, which mandates the systematic identification of climate and environmental risks in valuation reports. These include, at minimum: wildfire, river flooding, coastal flooding, desertification, seismic hazard, and volcanic hazard. Where market conditions reflect environmental or climate factors in price formation, and it is technically feasible to incorporate them into valuation methods, these risks—along with the property’s energy efficiency rating, if available—should be considered in the valuation outcome.	No
c) Are digitised tools and AI applied in order to capture and/or measure the impact of ESG factors and climate risk on property values?	NO	There are digitised tools and AI solutions that assess ESG factors and climate risks of a property. These tools are not publicly available, as they were developed by private companies.	Usually the bank conducts this assessment internally. Based on the results, it determines the interest rate.	Yes, digital tools and geospatial data are use to identify to what extent the assessed properties are exposed to climate risks		Yes, digital tools and geospatial data are increasingly used to capture climate risks such as flooding or transition risks.	not yet	Valuation standards such as the Red Book recognise the use of valuation models, advanced analytics, automation and AI-assisted processes, provided that they are appropriately governed and subject to professional judgement. The Red Book requires valuation models to be tested, documented and monitored, and specifically states that no AVM or AI-generated output can constitute an IVS-compliant valuation without the additional application of professional judgement by a qualified valuer.	No	Currently there are not digitized tools or AI applications involved in the assessment of the ESG factors and C&E risks in the property values; ISP has developed and internal model to assess them, based on publica data at national level (i.e. national database ISPRA for C&E hazard, construction and reconstruction average costs) and scientific publications (for example on the damage function). Database ISPRA: https://beta.idrogeo.isprambiente.it/app/pir	The Banks must monitor these risks, and the existence of these tools are very useful in this activity.	not yet	Yes, several valuation firms and technology providers are increasingly applying digitalised tools to integrate ESG factors and climate risk into property valuations.	Yes
I.6 Market Initiatives
a) Please describe any market initiatives which have been undertaken in your Member State (including cross border initiatives) and which have promoted market best practices and/or transparency of valuation practices.			• ČBA PSOM - Czech Banking Association – Working Group for Real Estate Valuation - Harmonization of bank valuation requirements. • RICS Czech Republic • Academic/professional body activities: o ČKOM (Czech Chamber of Property Valuers) o EXFOS (Expert Forensic Science) o KSZ ČR - Chamber of Court Experts of the Czech Republic o AZO – Association of Experts and Valuers of the Czech Republic	No market initiativs have been identified
II. THE VALUER
II.1 Regulatory Framework
a) Is property valuation a regulated profession in your Member State (through legal, regulatory or statutory rules)?	YES – through the National Valuation Act and the Chamber of Independent Appraisers (CIAB).	Property valuation is a regulated profession. According to the Law on Real Estate Valuation, the valuation report is a document that clearly and transparently presents the valuation of a property in written form, and it may be prepared by certified court experts or certified court valuers.	Yes with relevant education – after 3y experience this person could reach certification exam, and its is required to recertificate after each 5 years. Continual education is required to keep this certification (25 hours minimum per annum)	No, but CRR article 229 (1a) and section 7.3. in the EBA guidelines on loan origination and monitoring apply for Danish mortgage lending	The title "Valuer" is not protected by law in France	No, but there are national requirements for the qualification of valuers in the context of lending (see Question 2.1.c).	Under Hungarian regulations, engaging in professional real estate valuation activities requires at least a secondary-level general education and a specialized qualification in valuation, as well as registration in the central commercial register (National Register of Real Estate Valuers). Key applicable laws and recommendations include: - Decree No. 25/1997 (VIII.1.) of the Ministry of Finance (Annex 4 specifies the content and formal requirements of valuation reports, applicable for mortgage lending value determinations and generally followed in practice) - Decree No. 54/1997 (VIII.1.) of the Ministry of Agriculture - Act XXX of 1997 - Act LXXVIII of 1997 - Government Decree No. 253/1997 (XII.20.) - RICS Valuation Standards (Red Book, 6th edition, April 2010) - TEGoVA European Valuation Standards (EVS) - IVSC International Valuation Standards (IVS 2010) - Recommendation No. 11/2018 of the Hungarian National Bank (on managing real estate-related risks by financial institutions) - Recommendation No. 15/2021 (X.29.) of the Hungarian National Bank (on managing real estate-related risks by financial institutions)	No. Property valuation is not a statutorily regulated profession in Ireland, and the title “valuer” is not protected by legislation. Rather, the profession operates principally through professional self-regulation and market requirements.	In Italy, property valuation may be performed by several professional figures; in particular, valuation reports can be carried out by professionals registered with official professional bodies such as engineers, architects, agronomists.	In Italy, property valuations may be performed by several professional figures; in particular, valuation reports can be carried out by professionals registered with official professional bodies such as engineers, architects, agronomists, surveyors, …	The property valuation is a regulated profession by national law.	Yes, property valuation is a regulated profession in Slovenia. It is governed by the Slovenian Audit Act (ZRev-2), which defines the role of certified appraisers and sets the conditions for obtaining and maintaining a license.	Please refer to 2.2(a).	No
b) Is the use of the title of valuer protected in your Member State? If yes, by whom?	YES - bi CIAB	The profession of certified court experts and certified court valuers is regulated by the Judiciary Act (Official Gazette 28/13, 33/15, 82/15, 82/16, 67/18, 60/22, 21/22, 16/23, 155/23 and 36/24) and the Regulation on Certified Court Experts (Official Gazette 38/14, 123/15, 29/16, 61/19).	NO. Only individual insurance is possible.	In general no, but “DiplomValuar” and “Diplom i Vurdering” are protected titles for persons with these qualifications provided by the Danish Association of Chartered Estate Agents and recognised by the Danish authorities . A number of Danish valuers have the protected title Member of the Royal Institution of Chartered Surveyors (MRICS)	The title "Valuer" is not protected by law in France	No	Yes, the valuer’s role is protected to some extent. Valuers have to have education an licence. To practice the profession, one must be listed in the official chamber register (National Register of Real Estate Valuers)	No	The title “valuer” is not legally protected; however, the use of officially recognized professional or certified designations—such as those issued under UNI 11558, TEGoVA’s REV/TRV accreditations, or the RICS (Royal Institution of Chartered Surveyors) certification—is strictly regulated by their respective accredited or professional bodies.	The title “valuer” is not legally protected; however, the use of officially recognized professional or certified designations—such as those issued under UNI 11558, TEGoVA’s REV/TRV accreditations, or the RICS (Royal Institution of Chartered Surveyors) certification—is strictly regulated by their respective accredited or professional bodies	The use of the title of valuer is protected by national law and all valuers that are allowed to perform valuation reports for lending purposes must be authorised by ANEVAR.	Slovenian Audit Act (ZRev-2) regulates the expert areas associated with valuations and the supervision of valuations and the operations of the Slovenian Institute of Auditors and the Agency for the Public Oversight of Auditing and the Act (ZRev-2) also defines who is a certified appraiser. The supervisory authority is the Slovenian Institute of Auditors or the Agency for the Public Oversight of Auditing. The Institute shall carry out adopting and publishing professional valuation rules, defining the hierarchy of rules, defining the professional competencies and experience required to perform the tasks of certified appraiser, organising professional training, carrying out examinations of professional competence and issuing certificates regarding professional competence, supervise the work of certified appraisers, maintaining registers of certified appraisers.	Please refer to 2.2(a).	No
c) If the title of valuer is not protected in your Member State, how do lenders ensure that they work with ‘qualified’ valuers? Are there ‘professional’ certifications for property valuers in your Member State? If yes, please name them.	YES. According to the National Valuation Act, there are nine different specializations, each requiring a separate certificate—for example: real estate properties, plant, machinery and equipment, agricultural land, business valuation, intangible assets, financial instruments and institutions, etc. Each valuer holding a certificate is listed in the National Register of Independent Valuers.		All lenders based on Czech Banking Association keeping white list cooperating partners (circa more than 1200 in the Czech Republic) – these individuals/companies should be at least certified, often with insurance, educated by lenders on regular basis. There is also black list with valuers which did not follow standards in the past.	The requirement for the valuer to be independent and have the necessary qualifications, ability and experience to execute the valutation in CRR article 229 (1a)applies. Furtheremore, section 7.3. in the EBA guidelines on loan origination and monitoring apply for mortgage lending. Banks will do different quality controls. The Danish Valuation Order precribes control of external valuations: "The institution must perform a prior to execution regular and thorough spot checks with inspection of an appropriate share of the external valuations based on assessment reports."	The title "Valuer" is not protected by law in France. Lenders ensure quality by requiring certifications such as REV, MRICS/FRICS RV, or membership in recognized bodies like AFREXIM or SNPI.	In accordance with § 16 of the PfandBG and § 6 of the BelWertV, valuers must have professional experience in the valuation of properties and demonstrate expertise in determining Mortgage Lending Values. The BelWertV assumes that a valuer is sufficiently qualified if they have been appointed or certified as an expert or valuer for the valuation of properties by a state, state-recognised or DIN EN ISO/IEC 17024- accredited body. This includes HypZert GmbH: it is the largest accredited certification body for valuers in Germany with more than 2,400 certified individuals. To register for the certification exams, applicants must demonstrate many years of relevant professional experience, among other things. HypZert valuers are subject to strict professional principles. To maintain their certification, they must undergo continuous further training. Certain concessions apply with regard to qualifications and independence in the small loan sector pursuant to § 24 BelWertV. Other recognised qualifications include RICS and the public appointment and swearing-in of valuers.		Valuers instructed by lenders must be Red Book or Blue Book valuers.	Please refer to the previous answer 2.1 b)	Please refer to the previous answer 2.1 b)	Not applicable.	Professional certifications for property valuers: A certified business appraiser, certified appraiser of machines and equipment and a certified real estate appraiser	Not applicable.	Individual banks can also do quality controls, but those differs between banks. Many banks require membership in valuer organisations or estate agents’ organisations. There are different forms of certifications such as “Valuer authorized by Samhällsbyggarna” and “Valuer certified by Members of the Royal Institution of Chartered Surveyors (MRICS)
d) Is the regulatory or professional framework the same for all valuers, whether they value residential and/or commercial property? Or are there differences? Please describe as appropriate.	YES it is the same	The regulatory and professional framework is the same for all valuers, regardless of the type of property being valued.	In terms of sector residential or commercial there are not specific professional framework.	The regulary framework is the same		Professional requirements are broadly similar for residential and commercial valuers, but complexity and experience requirements differ in practice. Certain concessions apply with regard to qualifications and independence in the small loan sector pursuant to § 24 BelWertV. Valuers in the small loan sector must be sufficiently trained and qualified to determine the Mortgage Lending Value of the relevant properties within the small loan limit.	There is no difference in the legal framework. In Hungary, colleagues are usually only allowed to value non-residential properties after sufficient professional experience.	The overarching professional framework is broadly the same for both residential and commercial valuers. In practice, valuers are expected to comply with the same core professional standards relating to ethics, independence, competence, continuing professional development, conflicts of interest and valuation methodology, including the requirements of the Red Book or the Blue Book. However, differences arise in the competencies, experience and technical expertise required for different asset classes. While a valuer may be qualified to undertake both residential and commercial valuations, professional standards require valuers to possess the necessary knowledge, skill and experience relevant to the specific property type and valuation assignment.	The general regulatory and professional framework for property valuation is the same for all valuers, regardless of whether they appraise residential, commercial, industrial, or special-purpose properties	The general regulatory and professional framework for property valuation is the same for all valuers, regardless of whether they appraise residential, commercial, industrial, or special-purpose properties	The regulatory and professional framework is the same for all valuers, irrespective of the type of real estate.	The same.	In Spain, the regulatory and professional framework is the same for all valuers, regardless of whether they value residential or commercial property.	There are different authorisations for residential and commercial property, as well as special authorisations for specific property types, such as agricultural properties.
II.2 Qualification and Independence
a) The qualified valuer • How has the regulator in your Member State transposed the requirements of Article 19(2) of the MCD, of Articles 229(1) and 208(3b) of the CRR regarding the instruction of “professionally competent valuers” or valuers who possess the “necessary qualifications, ability and experience” (transposition through legislation or by self-regulation)? Indicate how professional competence and qualification requirements are prescribed.	Each valuer holding a specific certificate must first pass an examination organized by the CIAB. After successfully passing the exam, the valuer receives the certificate and is authorized to appraise only the type of assets for which they are certified. Each valuer must meet specific requirements: hold a bachelor’s or master’s degree and comply with the National Valuation Code of Conduct.	Pursuant to Article 3(2) of the Real Estate Valuation Act, real estate valuations shall be carried out by court experts and court valuers, whose authority derives from specific provisions regulating court and expropriation procedures. The requirements and conditions for appointing valuers are prescribed by the Judiciary Act (Official Gazette 28/13, 33/15, 82/15, 82/16, 67/18, 60/22, 21/22, 16/23, 155/23, and 36/24). As court experts, the Ministry of Justice, Public Administration and Digital Transformation may appoint persons who, during the nomination procedure, have been found to meet the following criteria: • are citizens of the Republic of Croatia, of a Member State of the European Union, or of a state that is a signatory to the Agreement on the European Economic Area; • have completed an undergraduate and graduate university study, an integrated undergraduate and graduate university study, or a specialist graduate professional study, or have completed an undergraduate university or undergraduate professional study corresponding to the field of expertise for which they are being appointed; • have at least eight years of professional experience after completing a graduate or integrated study programme, or ten years after completing an undergraduate study programme; • are proficient in the Croatian language; • are medically fit to perform the duties of a permanent court expert; • have successfully passed a knowledge test on the structure of the judicial system, public administration, and legal terminology; • have concluded a professional liability insurance contract for performing the duties of a permanent court expert, with a minimum coverage of EUR 25,000; • hold a valid authorization for independent professional practice (license) or have passed a professional or specialist examination required for the performance of that profession, if such a requirement exists under special regulations. A person subject to ongoing criminal proceedings or convicted by a final judgment for a criminal offense prosecuted ex officio — except for traffic safety offenses for which no unconditional prison sentence was imposed — may not be appointed as a permanent court expert. Before appointment, candidates for permanent court experts must successfully complete professional training, the content and procedure of which are prescribed by the Minister of Justice. Appointed permanent court experts are required to undertake continuous professional development in the field for which they have been appointed and to submit proof of such training to the Ministry of Justice at least once every two years.	The title “Expert” is regulated by Act No. 254/2019 Coll. (on Experts, Expert Offices, and Expert Institutes). The title “Valuer” (outside of expert activities) is not a protected designation; therefore, banks require relevant qualifications/certification and practical experience.	The mentioned articles apply for Danish mortgage lenders althout the articles are not reproduced in the Danish regulationm. Banks apply extenjsive internal traning of valuers. The DFSA frequently performs random sample checks hereby controlling that the valuers possess the necessary qualifications, ability and experience		The national implementation of the MCD in the German Civil Code (BGB) and the German Banking Act (KWG) does not specify these terms. Section 18a (7) of the German Banking Act (KWG) states the following: "(7) […] 2. ensure that internal and external valuers who carry out property valuations for them are professionally competent and sufficiently independent from the loan granting process to be able to carry out an objective valuation. [...]" However, Article 19(1) MCD (“professionally competent valuers”) is effectively implemented through a combination of statutory requirements (BelWertV, PfandBG) and supervisory expectations under MaRisk. In accordance with § 16 of the PfandBG and § 6 of the BelWertV, valuers must have professional experience in the valuation of properties and demonstrate expertise in determining Mortgage Lending Values. The BelWertV assumes that a valuer is sufficiently qualified if they have been appointed or certified as an expert or valuer for the valuation of properties by a state, state-recognised or DIN EN ISO/IEC 17024- accredited body. (See Question 2.1)	Hungary enforces the requirement for “professionally competent valuers” through a combination of national legislation (Government Decree 462/2015), professional self-regulation, and direct application of CRR. Competence is defined by independence, formal qualifications, and experience, with standards prescribed via law and professional guidelines aligned to IVS/EVS and RICS.	The transposition recognises RICS Registered Valuers and TEGoVA valuers as ‘competent valuers’, having regard to their accreditation criteria and the auditing arrangements in place to assess the quality of valuations.	The requirements have been transposed in Italy through prudential regulation issued by the Bank of Italy Bank of Italy Circular No. 285 of 17 December 2013 (Part I, Title IV, Chapter 3, Annex A, Paragraph 2.2.1 https://www.bancaditalia.it/compiti/vigilanza/normativa/archivio-norme/circolari/c285/aggiornamenti/Aggiornamento-n-50-del-26-agosto-2025.pdf) and operationalized via self-regulation in the banking sector, through the Guidelines for the Valuation of Properties Used as Collateral for Credit Exposures. These guidelines (see requirement R.2.3 – Valuer’s definition - abi.it/download/linee-guida-per-la-valutazione-degli-immobili-in-garanzia-delle-esposizioni-creditizie/?wpdmdl=29018&refresh=69174232958261763131954) embody the banking sector’s harmonized interpretation of what “professionally competent valuers” and “independent” must be.	The requirements have been transposed in Italy through prudential regulation issued by the Banca d’Italia and operationalized via self-regulation in the banking sector, through the Linee Guida ABI; these guidelines (see requirement R.2.3 – Definizione di Valutatore) embody the banking sector’s harmonized interpretation of what “professionally competent valuers” and “independent” must be.	In Romania, the national regulator stated that valuations used by a bank must comply with IVS and ANEVAR Standards. In accordance with national laws, only valuers authorised by ANEVAR are allowed to perform valuations for lending purposes. Through these two aspects, a qualified valuer is a valuer authorised by ANEVAR.	The Slovenian Audit Act (ZRev-2). This Act regulates the valuation profession and defines who qualifies as a certified appraiser. The supervisory authorities are the Slovenian Institute of Auditors and the Agency for Public Oversight of Auditing, which can impose measures such as orders to rectify violations, reprimands, or license withdrawal. Also SPS 9 defines required qualifications of the valuer and the requirement for independence: "Meeting the condition of required qualifications means that the valuer holds a valid license to perform the tasks of a certified appraiser in accordance with the Audit Act (Official Gazette of the Republic of Slovenia, Nos. 65/08, 63/13 – ZS-K, 84/18, 115/21 and 85/24; hereinafter: ZRev-2). Article 229 of the CRR requires that both the valuer and the valuation process for secured lending are independent from the credit granting and credit decision-making processes. A certified valuer performing a property valuation for secured lending must not be involved in or have any interest in the outcome of the credit decision process. Any valuer who is involved in the credit decision process does not meet the independence requirement and must be excluded from the valuation process whose valuation will be used for secured lending." This framework ensures compliance with Article 19(2) of the Mortgage Credit Directive (MCD) and Articles 229(1) and 208(3b) of the Capital Requirements Regulation (CRR), requiring valuations to be performed by professionally competent and independent valuers	In Spain, Article 19(2) of Directive 2014/17/EU (Mortgage Credit Directive – MCD) has been transposed through Law 5/2019, regulating real estate credit agreements. Specifically, Article 13 of Law 5/2019 mandates that any property offered as collateral must undergo an appropriate valuation prior to the conclusion of the loan agreement. This valuation must be performed by a valuation company or service of a credit institution regulated under Royal Decree-law 24/2021, or a certified professional in accordance with Royal Decree 775/1997, and must be independent from the lender or credit intermediary. Royal Decree 775/1997 establishes that the homologation (Official Recognition by the Bank of Spain) of a Valuation Firm will be obligatory when valuing properties intended to serve as a guarantee for mortgages (origination and valuation update of mortgage collateral). Among the requisites for the homologation process, valuation firms are required to count on the following resources: -To have a minimum of 10 professionals, of whom at least 3 must be “linked valuers”—meaning they contribute exclusively to a single valuation company—bound to it on a permanent and exclusive basis. Their role is to ensure that valuation companies maintain sufficient and accurate knowledge of the real estate market in which they operate, and that applicable valuation standards, legal obligations, and incompatibility rules are uniformly and correctly observed. These “linked valuers”, in addition to holding the required educational qualifications, must also have a minimum of three years’ experience conducting valuations. -A minimum structure of technical and human resources, as well as internal control mechanisms to ensure an accurate knowledge of the situation and conditions of the real estate market in which the firm is operating, and that the applicable valuation regulations and legal obligations and incompatibilities are uniformly and correctly observed. With regards to the “professionals” contributing to the valuation work of the valuation firms, the Royal Decree 775/1997 establishes specific requirements for the professionals who shall be engaged in the valuation of properties by the valuation firm. These professionals, to be enabled by law to participate in the valuation of urban properties or land plots intended to contain residential buildings, must be “architects and/or building engineers”; for the rest of property classes, they must be “engineers of the correspondent specialty, depending on the nature of the valued property”. With respect to Articles 229(1) and 208(3b) of the CRR, since the Capital Requirements Regulation is directly applicable across all Member States, no transposition into national law is required. However, the requirements regarding the necessary qualifications, ability, and experience of valuers have already been effectively addressed in the previous paragraph	This is implemented by law (SFS 2016:1024) and regulations (FFFS 2016:29). The term is not defined in any specific way. EBA guidelines are applicable in Sweden.
a) The qualified valuer • If professional competence, qualification, ability and experience requirements are not prescribed, what is general practice with regard to professional qualifications?	Only certified valuers are authorized to prepare valuations.	Competence requirements are regulated by law as described above. 3	Banks require practical experience, education, and certification according to ISO/IEC 17024. International designations (such as RICS or REV by TEGoVA) are also common. The ČBA Standard specifies requirements and the selection process for valuers.	N/A			In addition to advanced real estate appraiser training, banks require liability insurance. Also, the appraiser must be a member of a professional professional organization (MAISZ, TEGoVA, RICS). Professional experience is also a basic requirement for cooperation. A clean criminal record is also required.	A property-related degree (Level 8 or above), together with Chartered Valuation Surveyor status. The APC assessment is conducted by SCSI/RICS, typically following two to three years of professional experience, and includes a written submission, presentation and interview. Membership of the RICS Valuer Registration Scheme (VRS) is also generally required.		Please refer to previous answer 2.2 a)			Not applicable.	It differs between banks but it is prescribed with internal regulations. EBA guidelines are applicable in Sweden.
b) The independent valuer • How has the regulator in your Member State transposed the provision in Article 19(2) of the MCD or in Articles 229(1) and 208(3)(b) of the CRR regarding “sufficient independence from the credit underwriting process” or “independence from the loan processing and loan decision process” (through legislation or delivered through self-regulation)? Indicate whether and how the requirement is defined and whether and how it is prescribed.	The independence of valuers is defined in the National Valuation Act, officially titled - “Law on the Independent Appraiser.”	Pursuant to the Real Estate Valuation Act, the valuer is obliged to carry out the activities in respect of which he has been authorised in a professional, manner, independently and impartially, and he/she must present all the circumstances that bring into question his/her impartiality or a possible conflict of interest. The valuer shall sign a statement on impartiality and independence which is an integral part of the valuation report. If characteristics of the real estate in question exceed the competence limits of the valuer, he/she shall include, in the preparation of the valuation report, a professional with specific competences. The valuer shall draw up a valuation report in a correct manner and in line with regulations and rules of the profession. 4	The requirement for independence from the credit process is derived from Article 19(2) of the Mortgage Credit Directive (MCD) and CRR 208/229, and is operationalized in the EBA Guidelines on Loan Origination & Monitoring (LOM). Banks have internal independence barriers and conflict of interest rules.	The Danish regulation precribnes tht bankas must establish independent and regular internal controls to ensure segregation of duties and adequate valuations. During frequent inspections, the Danish FSA will assess whether sufficient segregation of duties is present or not and if the valuations are biased or subject to undue pressure .		The national implementation of the MCD in the German Civil Code (BGB) and the German Banking Act (KWG) does not specify these terms. Section 18a(7) of the German Banking Act (KWG) states the following: "(7) […] 2. ensure that internal and external valuers who carry out property valuations for them are professionally competent and sufficiently independent from the loan granting process to be able to carry out an objective valuation. [...]" However, Article 19(1) MCD (“independence”) is effectively implemented through a combination of statutory requirements (BelWertV, PfandBG) and supervisory expectations under MaRisk. According to § 7 BelWertV, valuers must be independent of the loan acquisition and loan decision-making process, as well as of property brokerage, sales and rentals. They must not have any family, legal or economic relationship with the borrower and must not have any personal interest in the outcome of their valuation report. Certain concessions apply with regard to independence in the small loan sector pursuant to § 24 BelWertV.	Points X. and XI. of Recommendation of the Hungarian National Bank - No. 18/2022. (XII.1.) apply here (on the management of real estate-related risks of financial institutions). Banks typically regulate this issue in their own regulations.	As above	Please refer to previous answer 2.2 a)	Please refer to previous answer 2.2 a)	The regulator stated that the valuation for lending purposes must be independent (the statement is without the sufficient part, which means the valuer must be fully independent) from the loan decision process.	SPS 9 defines required qualifications of the valuer and the requirement for independence: "Meeting the condition of required qualifications means that the valuer holds a valid license to perform the tasks of a certified appraiser in accordance with the Audit Act (Official Gazette of the Republic of Slovenia, Nos. 65/08, 63/13 – ZS-K, 84/18, 115/21 and 85/24; hereinafter: ZRev-2). Article 229 of the CRR requires that both the valuer and the valuation process for secured lending are independent from the credit granting and credit decision-making processes. A certified valuer performing a property valuation for secured lending must not be involved in or have any interest in the outcome of the credit decision process. Any valuer who is involved in the credit decision process does not meet the independence requirement and must be excluded from the valuation process whose valuation will be used for secured lending." This framework ensures compliance with Article 19(2) of the Mortgage Credit Directive (MCD) and Articles 229(1) and 208(3b) of the Capital Requirements Regulation (CRR), requiring valuations to be performed by professionally competent and independent valuers	As stated in response to question 2.2.a of this questionnaire, in Spain, Article 19(2) of Directive 2014/17/EU (Mortgage Credit Directive – MCD) has been transposed through Law 5/2019 of 15 March, regulating real estate credit agreements. This law does not modify the existing framework governing the competence and independence of valuation firms, which is established under Royal Decree 775/1997. Royal Decree 775/1997 establishes in its Article 13 that those professionals contributing to the issuing of valuations by Valuation Firms registered in the Bank of Spain will not be able to participate in the valuation of properties, assets, enterprises or patrimonies owned by persons or entities with whom the professional cannot reasonably maintain an independent position, affecting his objectivity during the valuation process. Same limitation applies to valuation firms when such conflicts of interest is detected affecting shareholders, members of the board and top officials of the firm. With respect to Articles 229(1) and 208(3b) of the CRR, since the Capital Requirements Regulation is directly applicable across all Member States, no transposition into national law is required. However, the requirements regarding sufficient independence from the credit underwriting process have already been effectively addressed in the previous paragraph.	Sufficient independence from the credit underwriting process” is defined in law, which states that the individual doing the valuation should be independent of the credit risk assessment.
b) The independent valuer • If “sufficient independence” is not prescribed, what is general practice to ensure the valuer is unbiased and not subject to undue pressure?	N/A	Sufficient independence is prescribed.		N/A			Financial institutions typically guarantee the involvement of independent contributors in their service contracts for lending and valuation.	This is set out in the Red Book, which states that valuers “must at all times act with integrity, independence and objectivity, and avoid conflicts of interest and any actions or situations that are inconsistent with their professional obligations”.		Please refer to previous answer 2.2 a)			Not applicable.	Not applicable. See above.
II.3 External vs. Internal
a) Does the legal or professional framework in your Member State specific to the valuation of property for lending purposes lay down rules for banks and lenders as to whom they may use to value properties? • If yes, do credit institutions have the possibility to employ both internal and external valuers? • Is one type of valuer typically employed more frequently than the other?	Banks may use both internal and external appraisers. All appraisers must be certified by the CIAB and listed in the National Register of Valuers. Usually, it is balanced between internal and external valuers. External valuers typically have an agreement with the bank that includes specific requirements.	Credit institutions may use only qualified and certified valuers who meet the legal requirements of professional competence, independence, and professional liability. Credit institutions have the option to employ both internal and external valuers, depending on their chosen or preferred operating model. External valuers are used more frequently than internal ones.	General law does not restrict this;	Valuers may be either internal (employed in a mortgage bank) or external to the lending institution . However, there is a long tradition in Denmark that the individuals carrying out property valuations in connection with mortgage lending are employed by the lending mortgage bank . The mortgage banks consider that valuation is an integral part of the lending process, for which the manage ment of the mortgage bank is responsible . External valuers are primarily used for valuation of private residential properties and are mostly real estate agents specialised in valuation with supplementary education . In order to use external valuers the mortgage bank with covered bond funding must give detailed valuation instructions and must carry out regular and thorough random sample checks by inspecting an appropriate percentage of the external valuations .		German banks do not necessarily commission external valuers for Market and Mortgage Lending Value assessments: many credit institutions also employ internal valuers or have valuers in their own subsidiaries. In its high requirements for independence, qualification and experience, the BelWertV does not differentiate between internal and external valuers. The proportion of internal and external valuations varies greatly from bank to bank and is subject to each bank's individual organisation of the valuation process. While some banks use almost exclusively internal appraisers, others outsource the vast majority of their valuations to external valuers.	The Bank’s internal regulations set out the professional requirements for valuers and define the procedure for selecting the individual responsible for the valuation. Yes. No.	As above Yes. Credit institutions employ third-party external valuers to independently value properties. Then often, the main large banks employ internal valuers to review draft valuations by the third-party external valuers before sign-off. Internal valuers also intermittently review existing third-party valuations between valuation instructions. As above.	yes through prudential regulation issued by the Bank of Italy Bank of Italy Circular No. 285 of 17 December 2013 (Part I, Title IV, Chapter 3, Annex A, Paragraph 2.2.2 https://www.bancaditalia.it/compiti/vigilanza/normativa/archivio-norme/circolari/c285/aggiornamenti/Aggiornamento-n-50-del-26-agosto-2025.pdf) Italian banks adopt different approaches. For example: - the internal valuers are used to review all appraisals that have a financing amount greater than € 3 million for the corporate segment and € 1 million for the individual segment - there is exclusive use of external experts and there is no preference whatsoever, as appraisal tasks are assigned randomly through a computerized process.	Yes, credit institutions have the possibility to employ both internal and external valuers In principle external appraiser are more frequently employed; ISP use external appraisers mainly for RRE sector and internal appraisers for CRE sector.	The legal framework states that valuations must be performed by ANEVAR authorised valuers. Credit institutions are allowed to use both internal and external valuers. The vast majority of the valuation reports used by the banks are performed by external valuers.	The legal framework requires banks to use certified valuers. Yes. Mortgage origination: more frequently external valuers. In the process of monitoring and review of property values, revaluation more frequently internal valuers.	Yes, credit institutions must employ valuation companies approved and registered by the Bank of Spain. No, credit institutions must use independent, external valuation firms certified and in good standing with the Bank of Spain requirements. Not applicable.	Valuers need to be sufficiently competent and independent Yes. It differs between banks
b) If there is/are no legislation/rules regarding the use of external and internal valuers, what is typical practice?	There are no specific rules in place.	It is common practice for credit institutions to use the services of both external and internal valuers, depending on their needs.	In practice, Czech banks commonly use both external and internal valuers. The choice depends on internal capacities and the bank’s internal policies.			There is no typical national practice. As described under a), the structure of the valuation process varies greatly in this regard.	Most financial institutions (the most significant real estate valuation clients in terms of numbers) work with contracted partners. In the vast majority of cases, the procedure is done by external evaluators, but there are also cases when an internal professional makes the report.	For new lending, external valuers are required.		No, there are no legislation/rules regarding the use of external and internal valuers; however, ISP has adopted internal regulations to regulate the use of internal and external valuers.	Not applicable.	Mortgage origination: more frequently external valuers. In the process of monitoring and review of property values, revaluation more frequently internal valuers.Internal valuers must also meet professional competence requirements and act independently from credit granting decisions.	Not applicable.	It differs between banks.
II.4 Professional Indemnity Insurance
a) Does the legal or professional framework in your Member State specific to the valuation of property for lending purposes require: • Valuers to have professional indemnity insurance cover? • Lenders to use only valuers covered by professional indemnity insurance?	Yes. Yes.	Professional liability insurance is mandatory. Proof of renewal of the insurance policy must be submitted to the competent Ministry of Justice, Public Administration and Digital Transformation each year. If a certified valuer does not have valid professional liability insurance, the competent Ministry revokes their licence to operate.	There is no general statutory obligation for valuers to hold professional indemnity insurance; however, banks require it contractually. The ČBA Standard regulates liability towards the bank (under § 2950 of the Civil Code) and sets qualification criteria for the selection of cooperating valuers.	Internal valuers do not have insurance covering errors in valuations . Such errors are the risk of the mortgage banks as employer . Due to the conditions for lenders with covered bond funding using external valuers, questions are very seldom raised regarding indemnity between the mortgage bank and the external valuer . External valuers are under no obligation to have insurance covering the risk of errors made in connection with the valuation task . In the agreement between the mortgage bank and the valuer, insurance may be requested but it is not usual practice . Estate agents are legally obliged to have indemnity insurance in relation to their purchasing and selling activities . However, the insurance only covers estate agent valuations ordered directly by the consumer, and not valuations ordered by professionals including mortgage banks . There is no legislation which determines exactly what the valuer is responsible for vis-à-vis his client . However, the valuer can be liable according to general Tort Law and based on the contract between the lender and the valuer regarding the valuation . There is however a special regulation regarding estate agents’ liability		No	Yes. Yes.	Valuers to have professional indemnity insurance cover? Yes Lenders to use only valuers covered by professional indemnity insurance? Yes		Yes for both	The legal framework specific to the valuation of properties state that valuers must have a valid professional indemnity insurance cover. This is also a requirement as to maintain the status as an authorised valuer and thus, lenders only use valuers which are covered by professional indemnity insurance.	This obligation is linked to the regulatory framework under the Slovenian Audit Act (ZRev-2) and professional standards, ensuring that valuers have financial protection against claims of negligence, errors, or omissions when performing valuations for secured lending or other purposes. This requirement is part of the regulatory framework under the Slovenian Audit Act (ZRev-2), professional standards and internal bank rules.	Yes. Valuation firms authorised by the Bank of Spain are required to maintain professional indemnity insurance as a condition of their approval under Royal Decree 775/1997. In addition, it is common practice for valuation firms to require external valuers (i.e. independent professionals who collaborate in the issuance of valuation reports) to hold professional indemnity insurance covering their valuation activity. Yes, lenders may only use valuation firms which must have professional indemnity insurance.	Yes, valuers authorised by the Royal Institution of Chartered Surveyors (RICS) and Samhällsbyggarna. No
b) If there are no such requirements, how are lenders/valuers covered for the risk? • Is/are there legislation/rules in your Member State determining the responsibility of the valuer vis-à-vis his client? If yes, please describe the legislation/rules and the responsibility of the valuer.	Each client has the right to challenge a valuation or report an unprofessional conduct to the Ethics Committee at CIAB. The responsibility of the valuer is both criminal and administrative.	Valuers who work for e.g. banks, investors, companies, etc., operate under a contractual relationship with the client commissioning the valuation. Their liability towards the client is governed by: • Law on Real Estate Valuation (Official Gazette 78/15), • Civil Obligations Act (Official Gazette 35/05, 41/08, 125/11, 78/15, 29/18, 126/21, 114/22, 156/22, 155/23) – in the part relating to liability for damages and the performance of a contract for services. A valuer bears civil/financial liability if : • fails to apply the legally prescribed valuation methods, • provides an incorrect or unprofessional valuation opinion, • causes financial damage to the client due to negligence or omission. The competent Ministry of Justice, Public Administration and Digital Transformation may also initiate supervisory or disciplinary proceedings, and in serious cases revoke the valuer’s authorisation.		See the answer to question above	Mandatory for all professional valuers under national professional standards.	it is common practice to work only with valuers who can prove professional indemnity insurance.	We are not aware of such a rule. Generally, the provisions of the Civil Code and the Criminal Code apply.			Please refer to previous answer	As per current legislation, valuers are liable for any damages caused by valuation reports which are not performed in compliance with ANEVAR Standards.	This requirement is part of the regulatory framework under the Slovenian Audit Act (ZRev-2), professional standards and internal bank rules. The bank concludes cooperation agreements with valuers and includes only those valuers on its list who have a valid professional indemnity insurance policy in place. This requirement is part of the regulatory framework under the Slovenian Audit Act (ZRev-2) and professional standards. It ensures that valuers have financial protection against claims for negligence, errors, or omissions when performing valuations, particularly for secured lending purposes. The insurance covers legal defense costs and potential compensation claims, providing security for both valuers and their clients.	Not applicable.	Not applicable.
III. VALUATION & CAPITAL REQUIREMENT
a) Property Value How are the Property Value requirements of Article 229(1) CRR transposed in your Member State: • by calculating the Mortgage Lending Value • by Market Value adjustments ◦ adjustments determined by the valuer on a single property by property basis ◦ adjustments determined by the credit institution on a portfolio level based on internal historic market data series ◦ adjustments determined by the credit institution on a portfolio level based on data provided by external research institutes or data providers	Currently, there is no specific guidance regarding the new ‘Property Value’.	The mortgage lending value is currently not formally defined or prescribed under Croatian legislation as a separate basis of value. Regular annual checking of the non residential real estates done by official appraisers based on official appraisal done by OTP real estate company. Market Value of residential real estates is regularely adjusted using official indexes published by Croatian Bureau of Statistics.	by Market Value adjustments	By the use of market values adjusted by the banks on a sub-portefolio level based on internal historic market data series.	France does not apply Mortgage Lending Value (MLV) as a distinct statutory or professional valuation basis. Property Value is determined through Market Value, complemented by prudential adjustments applied by credit institutions, in line with CRR and ACPR supervisory expectations.	The national banking supervisory authority has stated that two approaches are possible for the operationalization of "property value" in Germany: - The mortgage lending value pursuant to Section 16 (2) sentences 1 to 3 Pfandbrief Act in conjunction with the Regulation on the Determination of Mortgage Lending Values of Properties (Beleihungswertermittlungsverordnung (BelWertV)) fulfills the requirements of Article 229 (1) CRR in all cases. - Alternatively, the market value can be used as a basis. In a step downstream of the market value determination, this value must be reviewed to determine whether an adjustment is necessary in order to meet the requirements of Art. 229 (1) letter b) CRR III. While the market value is of course determined on a property-related basis, this review and, if necessary, adjustment of the market value can be carried out on a portfolio-related basis using statistical methods of relevant market data. With regard to the second alternative, there are no guidelines as to whether the bank should work with discounts based on internal historical market data series, external research institutes or data providers. All mentioned variants are possible. One widely used methodology is an adjustment approach developed by the Association of German Pfandbrief Banks in cooperation with vdpResearch: vdpResearch	Hungary does not issue separate legislation; Article 229(1) CRR applies directly. From January 2025, Hungarian banks must use the Basel III-aligned “Property Value” concept for immovable property collateral, ensuring independent, conservative valuations, historical averaging, and sustainability adjustments. MNB supervises compliance, and banks are updating internal policies accordingly. Hungary has its own legislation for calculation the mortgage lending value. This is written in the 25/1997 Ministry of Finance decree. This is not considered to be equal with the property value. The Market Value adjustment is not reqired according to the referring guidance of the Hungarian National Bank (MNB). No. Yes. No		Currently there is not a unique, clear and formal transposition of the Article 229 (1). A specific methodology has not yet been defined. In general, In Italy, the property value is determined and provided by the appraiser - a natural person or a subject organised in the form of a company or association - as required by the CRR The “guidelines for the evaluation of properties used as collateral for credit exposures” are aligned with the Regulation (EU) 2024/1623 amending Regulation (EU) No 575/2013. Notably, the guidelines introduce the concept of "Property Value " and the description of the requirements that valuation of immovable property shall meet in order to take into account the provisions of Regulation (EU) 2024/1623. The guidelines report that, taking into account the provisions of the art. 229, paragraph 1, letter b), point (ii), the "Property Value" could be "derived" from the market value " where such market value can be determined;" Considering that the elements that characterize the definition of the market value are not entirely satisfied, in estimating the "Property Value" it seems appropriate, inter alia, to refer to specific assumptions which must be rational, objective ( or at least plausible) and motivated. In this regard, the valuer could determine possible scenarios of evolution of the real estate cycle of the market segment to which the property belongs in order to express an opinion regarding the placement of the market value of the property being estimated within the identified cycle. In a profoundly evolving valuation scenario, which requires further investigation, the ABI guidelines working group is working to develop a specific methodological Appendix on the determination of the "Property Value" as this methodology has not yet been defined in detail for this value.	Currently there is not a unique, clear and formal transposition of the Article 229 (1); the Linee Guida ABI refers to the requirement R.5 and in particular to the R.5.5: “…Property Value could be derived from the market value where the latter can be established”. As far as it concerns ISP, the property value is derived by market value adjustments (market trends, marketability, transition risk, flood and landslide risks) determined by the valuer on a single property.	The property value is determined by the credit institution. Each bank is allowed to estimate it using different methodologies – adjustments determined by the bank using internal data or information supplied by extern providers.	There is no Mortgage Lending Value in Slovenia. The Bank of Slovenia stated that the term "market value" is no longer used for the valuation of real estate, but has been replaced by the term "value of real estate," assessed on the basis of prudent and conservative valuation criteria. No further explanations were provided. Therefore, through the Slovenian Banking Association, we contacted the Institute of Auditors (SIR) – Real Estate Valuation Committee and obtained an expert opinion. SIR has defined correction factors to assist property valuers in determining value using a prudent valuation method (»prudent value«). The SPS 9 (2025) - Slovenian standards, stipulates that each valuation report must state the market value and »prudent value«. The bank always obtains the prudent value in individual valuations, which it reports in accordance with capital adequacy requirements. In the process of monitoring property values, the index is always applied to market value.	Under the amended Article 229(1) of the CRR, EU Member States are required to adopt a property value that must not exceed market value and must be determined using prudently conservative criteria. This value must exclude expectations of future price increases and be adjusted to reflect the possibility that current market prices may significantly exceed the level that would be sustainable over the life of the loan. In Spain, mortgage valuations have long followed the principle of prudence, as established in Article 3.1.f) of Order ECO/805/2003, which states that when faced with several equally probable scenarios, the one resulting in the lowest valuation must be selected. The regulation also requires valuations to exclude speculative price increases, particularly those driven by artificial market distortions. This is reflected in the definition of mortgage lending value provided in Article 4 of the same Order (see response to question 1.2.b). If there is a high risk that current market values may not be sustainable over time, adjustments must be made to reflect potential long-term declines. According to the Order ECO/805/2003, adjustments to market value must be applied under the following conditions: oThe valuation has been performed exclusively using the comparison method; and oThe valuation company estimates a high probability of a significant nominal value reduction within 18 months from the expiry date of the valuation. In such cases, the valuation company will determine the appropriate adjustment. If market data do not allow for a reliable estimate, a 10% reduction will be applied by default, or 15% if significant volatility is observed. Spain has not required a specific regulatory transposition of the principles set out in Article 229(1) of the CRR regarding the prudent valuation of real estate collateral, as its national framework has long applied functionally equivalent criteria. These principles are embedded in Order ECO/805/2003, which constitutes the methodological foundation for mortgage valuations in Spain, ensuring independence, prudence, and traceability. Building on this foundation, Bank of Spain’s Circular 4/2017 sets out the operational procedures requiring that the recoverable amount of real estate collateral be adjusted from its reference value by applying discounts that reflect estimation uncertainty, potential value declines up to the point of enforcement and sale, and associated costs (enforcement, maintenance, and disposal). These adjustments are determined using internal methodologies developed by the credit institutions themselves. Such methodologies must be based on historical experience in the sale of comparable properties, including data on prices, timeframes, volumes, and realisation periods. This experience is deemed sufficient when the institution has sold at least 10% of its average annual inventory and 75 properties of the same type. In addition, institutions must maintain complete and traceable internal databases capturing all relevant information from the time of repossession to derecognition from the balance sheet, thereby reinforcing the use of internal historical series as the basis for adjustments. As an alternative, the Spanish regulatory framework requires all institutions—regardless of the maturity of their internal models—to apply standardised percentage discounts in benchmarking exercises and in the preparation of regulatory reporting (statement FI 131-5.4). These discounts, set out in the table under paragraph 172 of Annex IX to Circular 4/2017, represent global adjustments to the reference value applicable to different types of foreclosed or repossessed real estate assets. It also includes a general reference on disposal costs, noting that these vary by asset type and should not, as a general rule, be considered lower than 5%. Furthermore, any limiting conditions or disclaimers identified by the valuer in the valuation report—particularly those arising from the inability to inspect the interior of the property—must be assessed by the institution to determine whether additional adjustments to the reference value are warranted, where such factors have not already been reflected by the valuer. Under the Spanish regulatory framework, this option is not envisaged for the estimation of the recoverable amount of real estate collateral. Bank of Spain´s Circular 4/2017 requires that adjustments to the reference value be determined using internal methodologies developed by the credit institution itself, based on its historical experience in the sale of comparable real estate assets. This experience must be both sufficient and traceable, and supported by complete internal databases. As an alternative, for institutions that have not developed such methodologies, the Circular mandates the application of standardised percentage discounts defined by Bank of Spain, as set out in the tables under paragraphs 138 and 172, both included in Annex IX. These discounts are not based on data provided by external research institutes or commercial data providers, but have been directly estimated by the supervisory authority based on its knowledge of the Spanish banking sector and established market practice.
b) Monitoring of property values Has the regulator in your Member State laid down criteria regarding "more frequent monitoring where the market is subject to significant changes in conditions"?	NO	No		No, the DFSA has not published any interpretations	Property values are monitored in line with CRR minimum frequencies (typically annually for commercial property and less frequently for residential property – every 3 years in general), with more frequent monitoring triggered by internally defined risk indicators rather than regulatory thresholds.	National banking supervisory authorities have stated that events that cannot be captured by general market developments may also necessitate a review of property values. These include technical, economic or environmental disasters such as natural disasters, regional property crises or specific borrower- or contract-related events. Individual institutions must have processes and models in place to identify such review events.	Hungary applies the CRR directly. Institutions must set internal criteria for “significant changes,” typically linked to MNB housing market indicators and macroeconomic factors. There is no fixed percentage in law, but thresholds like 10%+ price movement or major economic shocks are commonly used in practice.		No. In Italy, the provisions of regulation Regulation (EU) No 575/2013 apply. As answered in the previous question, The “guidelines for the evaluation of properties used as collateral for credit exposures” are aligned with the Regulation (EU) 2024/1623 amending Regulation (EU) No 575/2013. These guidelines report what is established by Article 208, paragraph 3, of Regulation (EU) No. 575/2013. It is up to the Banks to better lay down the monitoring requirements, by internal rules and policies.	General criteria have been embodied in the Linee Guida ABI, in the requirement 6.2 “Monitoraggio e riesame della valutazione”. It is up to the Banks to better lay down the monitoring requirements, by internal rules and policies.	The national regulator requires that all banks must increase the frequency of property monitoring in the event of a significant change in market conditions.	No	Yes. According to Bank of Spain’s Circular 4/2017, Annex IX, section 2.2.2, institutions must verify at least annually whether there are signs of significant declines in the value of real estate collateral. This verification may rely on market indices or the opinion of an independent valuer. If, as a result of this verification, a significant decline in the reference value is identified, the valuation must be updated immediately by certified and independent valuation companies, regardless of the regular update schedule.	No
b) Monitoring of property values Has the regulator in your Member State laid down criteria regarding “advanced statistical or other mathematical methods” complying with the technical requirements of Article 208(3a) CRR?	NO	No		No, the DFSA has not published any interpretations		No	Hungary applies CRR Article 208(3a) directly and supplements it with ministerial decree and MNB supervisory expectations. There is no separate Hungarian legal definition, but institutions must comply with EU-level technical criteria and MNB guidance, which require robust model governance, validation, and transparency.		See previous answer	General criteria have been embodied in the Linee Guida ABI, in the requirement 6.3 “Criteri per i metodi statistici o altri metodi matematici avanzati ("modelli")”. It is up to the Banks to better lay down the monitoring requirements, by internal rules and policies.	The national regulator has set up the criteria regarding “advanced statistical or other mathematical methods” as the ones in Article 208(3a) CRR.	No	Yes. Spain has laid down specific criteria for the use of advanced statistical methods, particularly automated valuation models (AVMs), in line with Article 208(3a) CRR. These criteria are reflected in three layers of regulation: 1.Bank of Spain’s Circular 4/2017, Annex IX, section 2.2.1, 78 b), already recognised AVMs as a valid valuation procedure, provided they are developed by certified and independent valuation companies, applied to homogeneous properties, follow generally accepted valuation practices, and are benchmarked against full individual valuations. 2.Order ECO/805/2003, Article 15 bis, introduced in the August 2025 update, formally regulates AVMs for the first time. It sets out technical requirements regarding property homogeneity, dual estimation of market and mortgage lending value, and robust methodologies. It also mandates that Bank of Spain develop further requirements via circular. 3.Bank of Spain´s Supervisory Guide on AVMs (2019), although predating the 2025 update, remains the operative technical reference. It outlines standards for data representativeness, model validation, internal controls, and prudent application. Until the new circular is issued, this Guide provides the applicable framework for AVM deployment in Spain.	No. Each lender has to explain and describe the model for the regulator. The regulator has the mandate to approve or decline the statistical method.
b) Monitoring of property values Please provide an overview of the different statistical methods/tools complying with Article 208(3a) CRR applied by lenders in practice.	There are no such methods or tools available.	OTP bank Croatia applies indexes on residential real estates published by Croatian Bureau of Statistics.		Signs of declining market values are identified by regular monitoring using updated published statistics and the banks knowledge of recent trends in local sales prices and rents per sqare meter for the different property segments		One of the statistical methods recognised by the national banking supervisory authority is the market fluctuation concept of the German Banking Industry Committee (DK, Deutsche Kreditwirtschaft). This has already proven itself for commercial properties since 2001 and for residential properties since 2007 for the implementation of the monitoring requirements at that time. The DK’s market fluctuation concept covers market developments for commercial property types such as offices, retail, warehouses and hotels, as well as residential property types such as condominiums, single-family, two-family and multi-family houses. With the exception of hotels, market fluctuations are provided for all cities and districts in Germany. For hotels, market developments are measured in selected indicator cities and four major regions in Germany and reported to BaFin. The results are made available to the supervisory authority on an annual basis. In addition to the market fluctuation concept of the German Banking Industry Committee, other statistical methods for monitoring values have been developed in recent years. In addition to institution-specific models, which are strongly oriented towards the respective financing portfolio, there are also cross-institutional products on the market. One example is the property market monitoring service provided by vdpResearch GmbH, which is used by over 90% of German credit institutions.	The most typical statistical method used in Hungary for the revaluation of real estates is indexation.		Some banks monitor the value of the collateral property frequently, at least annually for non-residential properties and once every three years for residential properties, using statistical methods independent of the credit decision process and meeting the conditions set forth in Article 208, paragraph 3-bis. In detail, banks monitor the value of properties securing mortgages semi-annually, using a statistical methodology based on real estate market indices provided by external providers. This methodology is based on an estimate of market value obtained from the initial origination appraisal and subsequent update reports, adjusted based on real estate market trends. This methodology is applied to both residential and non-residential real estate values.	Intesa Sanpaolo group has in place a dedicated tool («Fair Value Engine») in order to update real estate values on a monthly basis. It is fed with market data provided by external provider of solid reputation. In most cases Fair Value is calculated by applying to appraisal values historical data series that represent italian real estate market trends.	There are several AVMs and hybrid methods used in the monitoring processes, used only for properties which have a large enough population that can safely provide accurate results.	Parametric test: One- sample Student's t- test, confidence intervals.	In Spain, the use of statistical models for property value monitoring is governed by Bank of Spain’s Supervisory Guide on AVMs. According to Annex IX, section 2.2.1, 78 b), of Circular 4/2017, AVMs may only be applied to properties with a sufficient degree of homogeneity — meaning repeatable characteristics In addition, the recent update of Order ECO/805/2003 through Order ECM/599/2025, in force since 12 August, reinforces this principle by establishing that only properties with a certain level of homogeneity—defined as having characteristics suitable for repeated production and being located in an active transactional market—may be valued using automated models. Valuation companies are expressly prohibited from accepting valuation assignments unless they have verified the sufficiency and quality of the available data regarding the characteristics of the properties to be valued. This ensures that valuation companies have access to adequate data for mass processing and modelling. According to Bank of Spain’s Supervisory Guide on AVMs, Automated Valuation Models must adhere to generally accepted valuation standards and good practices, which include the following: - Hedonic regression models: These use multivariate statistical techniques (typically multilinear regression) to estimate property value based on key characteristics, including sociodemographic factors of the area. They require detailed property-level and location-specific data and may incorporate adaptive algorithms or artificial intelligence, such as neural networks. - Comparable models: These rely on selecting a sample of similar properties in the same area, with comparable construction features, surroundings, and market conditions, to establish a price relationship. - Mixed models: These combine elements of both hedonic and comparable approaches, with an added subjective component in the weighting of results. It is not considered good practice to simply index a previous valuation using general price indices. In some cases, AVM results may be adjusted by expert judgment or additional checks by a valuer. These are referred to as AVM (A) — assisted AVMs — which tend to be more accurate but also more resource-intensive.	In practice, commercial property price indices purchased on a regular basis from an external valuation company are used to monitor the last Market Value. These new indexed market valuations are then used for monitoring the development of LTV-ratios for example. For residential retail properties are AVM used as a general valuation method to monitor the last value.
c) Review of property values and revaluation • Has the regulator in your Member State laid down criteria which define “review” of the property valuation? If so, what are the minimum and maximum periods within which a review must be conducted? Based on which criteria?	No, usually we refer to Article 575: for RRE, the revaluation must be done every 3 years, and for CRE, annually.	No	Generally, these criteria are not explicitly defined; banks have adopted the criteria from the CRR regulation and implemented their own internal rules. At least annually for commercial properties and once every three years for residential properties; more frequently in the event of significant market changes. Statistical/AVM methods may be used for monitoring; large exposures (over EUR 3 million or 5% of own funds) require regular reviews by an expert	The DFSA precribes yearly revaluation if the LTV is above defined limits		Yes, it has to be reviewed whether the original assessments of the framework conditions and the other assumptions about the relevant market on which the valuation reports are based are still valid. If the assumptions and results at the time are no longer accurate, the value of the property must be revalued. In accordance with Article 208 (3) CRR, advanced statistical methods may be used to identify properties that require revaluation.	Hungary applies CRR directly: residential property valuations must be reviewed at least every 3 years, commercial annually, and more frequently if market conditions change significantly. The Hungarian regulator has not issued separate numeric thresholds but expects banks to define internal criteria based on market indicators and risk factors.		See answer letter a) with reference to the specific practices of the banks. some Banks fulfill their obligations regarding the monitoring of registered real estate and movable assets (ships and aircraft) held as collateral in accordance with the provisions of the CRR (Article 208). a) Banks monitor the value of the collateral property frequently, at least annually for non-residential properties and once every three years for residential properties, using statistical methods independent of the credit decision process and meeting the conditions set forth in Article 208, paragraph 3-bis. See answer lett. b) b) Banks conduct more frequent reviews if market conditions are subject to significant fluctuations. The property's valuation must be revised when available information indicates that its value may have decreased significantly compared to general market prices (the "validity from appraisal date" requirement). c) For mortgages exceeding €3 million or 5% of the Bank's regulatory capital, the assessment must be updated by an independent appraiser at least every three years. This requirement also applies to the Advanced Internal Rating Based (AIRB) portfolio. d) Banks, in accordance with the guidelines of the European Banking Authority (EBA), carry out annual monitoring of non-performing mortgage exposures whose residual debt exceeds €300,000. e) The review/update of the real estate value is carried out by an appraiser/appraisal company that has the necessary qualifications, skills and experience to carry out an assessment and that is independent from the credit decision process (so-called "independent appraisal" requirement) f) Banks must also monitor the value of ships and aircraft and update the appraisal on an annual basis, always by an appraiser/appraisal company that has the necessary qualifications, skills and experience to carry out an assessment and that is independent from the credit decision process	General criteria have been embodied in the Linee Guida ABI, in the requirement 6.2 “Monitoraggio e riesame della valutazione”. It is up to the Banks to better lay down the monitoring requirements, by internal rules and policies. As far as it concerned for ISP, the valuation of real estate assets must be updated individually according to internal rules which consider relevant, as the case may be, counterparty classification status, residual gross exposure value, adjusted loan-to-value ratio, latest available fair value, impairment rate and date of last valuation depending on the type of property ( 1 year for CRE, 3 years for RRE). Full, desktop or drive-by reappraisals are carried out depending on the status of the counterparty and, in particular: • in the case of counterparties classified as performing (including counterparties classified as proactive), desktop reappraisals are always performed; • in the case of counterparties classified as non-performing other than bad loans o real estate assets mortgaged as collateral for exposures: desktop reappraisals are always carried out, except for reappraisals carried out before credit granting decisions relating to the definition/review of the business strategy, if the strategy involves the liquidation or withdrawal from the relationship; in this case, a full reappraisal must be carried out (or drive-by if access to the premises is not possible), indicating not only the market value but also the immediately realizable value. In all other cases, when initiating the reappraisal process, the responsible management function always has the authority to request a full appraisal instead of a desktop appraisal if deemed appropriate; o real estate leases: a full reappraisal is always performed (drive-by if access to the premises is not possible); • a full reappraisal is always carried out for counterparties classified under bad loans (or drive by if access to the premises is not possible).	The criteria which defined the review process of property valuations are the ones from the EBA Guidelines.	no. The only regulation is CRR 3. The Bank of Slovenia instructs us to follow the EBA Q&A ourselves.	Please refer to 7(g)	No criteria, except in the rules for covered bonds requiring regularly.
c) Review of property values and revaluation • Has the regulator in your Member State laid down criteria which define “material decline relative to general market prices”? How are ESG-related considerations assessed as an indicator for a material decline?	NO, for ESG please refer to 1.5	No		No		Yes, if the regular monitoring reveals indications that the property may have lost considerable value in relation to general market prices, the valuation must be reviewed. The national banking supervisory authorities (BaFin and Bundesbank) have so far interpreted “significant” as meaning that, within a period of up to three years, general market value losses of more than 10% for commercial properties and more than 20% for residential properties have occurred. According to the German Banking Industry (DK), ESG factors do not need to be explicitly addressed in this context. As one of many potentially value-relevant components, they are already included in prices and values to the extent that the market attributes value to them. The above-mentioned statistical methods for monitoring are based on price measurement and therefore already implicitly include ESG factors.	Hungary has not set a statutory percentage for “material decline”. Relying on MNB supervisory expectations published in its recommendation banks defining internal threshold(often around 10%). ESG considerations are increasingly integrated through MNB’s 2024 ESG Recommendation, requiring data collection and risk assessment, but they serve as qualitative indicators rather than fixed triggers for valuation review.		No	No, there are not specific criterai stated in the ABI Guidelines; ESG-related considerations are not assessed as an indicator for a material decline.	The regulator has stated that in the event of a significant decline in general market prices, each bank must set a threshold which will trigger a more frequent monitoring of the collaterals.	no. There are no regulations from Slovenian authorities regarding "more frequent monitoring." However, the Slovenian Institute of Auditing determines each year what constitutes a significant change in the real estate market. The deviation is calculated by comparing fluctuations in the real estate sector with fluctuations in the economy as a whole in Slovenia. It is not mandatory to take this calculation into account. The majority of banks in Slovenia use the SIR calculation in the process of monitoring the value of real estate.	Bank of Spain has not issued a formal or quantitative definition of “material decline relative to general market prices.” However, Circular 4/2017, Annex IX, section 2.2.2, paragraph 81, requires institutions to verify at least annually whether there are indications of significant declines in the reference valuations of real estate collateral classified as performing. A similar obligation applies under paragraph 84 for exposures under special monitoring. This assessment should take into account relevant indicators such as the evolution of published indices on mortgage market prices, as well as the opinion of an independent valuer. If a material decline is identified, the valuation must be updated by certified and independent valuation companies. The regulation does not specify a numerical threshold or define “general market prices” as a technical concept, leaving the interpretation to the institution’s judgment based on available data and expert input. Regarding ESG-related considerations, valuation companies in Spain are required to consider environmental and climate-related factors when these are relevant to the local real estate market, as established in the updated Order ECO/805/2003. From the perspective of the independent valuer — in Spain, certified valuation companies authorised by Bank of Spain — environmental and climate-related criteria are an intrinsic part of how market value is constructed. In other words, real estate markets already reflect ESG-related factors implicitly through pricing mechanisms. However, the updated Order ECO/805/2003 now requires that environmental and climate factors be made explicitly visible in valuation reports whenever they are relevant to the formation of value. That said, it is a different matter to treat ESG considerations as indicators of a material decline in value. These are often linked to unpredictable phenomena, such as natural disasters, and are not currently defined as formal triggers for revaluation under the Spanish valuation regulatory framework. A recent example illustrates how ESG-related risks can be translated into valuation criteria through coordinated sectoral action. In late October 2024, a cut-off low over inland Spain caused intense rainfall and flooding across the Valencian Community, resulting in severe damage to infrastructure and property. In response, the AEV assessed whether common valuation guidelines were needed for the affected areas. Following consultation with Bank of Spain, it was agreed to apply a mortgage adjustment in the most severely impacted zones, given the absence of mitigation measures and the increased likelihood of future damage. AEV member companies analysed 28 identified areas to assess whether there was a high probability of nominal value decline within one year from the valuation date, with effects expected to last at least two years. This assessment combined qualitative surveys conducted by valuers on the ground with quantitative analysis. For the affected areas, a mortgage adjustment starting at 10% was applied to values determined by the comparison method, with further distinctions based on property characteristics (e.g., ground-floor units). The agreement was reviewed quarterly to monitor market evolution. The Valencia experience demonstrates the robustness of the Spanish valuation model—anchored in technologically advanced appraisal firms and expert valuers with deep local knowledge. It shows how ESG-related risks, when properly assessed, can be translated into concrete valuation criteria, reinforcing transparency and resilience in volatile market conditions.	No, not really. A decline by 15 percent has been mentioned but it is not explicitly mentioned in regulations. Adjustments are determined by the valuer on a single property by property basis, when relevant.
c) Review of property values and revaluation • Please provide a description of how ‘reviews’ are carried out in your Member State, e.g. by a new full-size valuation report, a desk-top valuation, a valuation certificate, a plausibility assessment or alike. What criteria are used to determine how the reviews are to be carried out?	“According to the National Valuation Act, there is only a description of initial valuation or post-control revaluation, which must be prepared individually with an on-site inspection. In the banking sector, some revaluations cloud be desktop-based, relying on market analysis without on-site inspection, and applied only for clients in Stage 1.”	Revaluation of residential real estates is performed using indexes on residential real estates published by Croatian Bureau of Statistics. For non residential real estates desktop valuations are being performed in the 5 year period since original official valuation, so every 5 years we make new official appraisal and in the meantime desktop valuation, except for properties securing exposures above 3 EUR where criteria is set to 3 years. General criteria are 3 years for residential and 1 year for non residential real estates according to the article 208 of CRR.		In general a desktop valuation is used which for investment property normally will require new informaation of the the rental income (rental lists). I certain circumstanses an inspection of the property is undertaken. The Danish mortgage institutions have their own business procedures.	Reviews are commonly performed through desktop or model‑based updates, while a full revaluation is required where a material decline or sensitive risk is identified.	Credit institutions must implement processes for reviewing property values. These are usually differentiated according to risk categories. In some cases, it is also up to the valuer to decide how thorough the review should be, for example, whether a desktop valuation is sufficient or whether an inspection should be carried out. There are no national guidelines on what constitutes a review.	In Hungary, reviews can be full on-site valuations, desktop valuations etc. MNB expects banks to define internal policies about what kind of valuations they accept in different cases.		Some banks, to monitor the value of registered real estate/movable assets, use the following statistical valuation criteria based on real estate market indices provided by external providers. Furthermore Banks identify the following specific categories of loans/relationships that require an analytical revaluation, unless otherwise specifically required to be assessed on a case-by-case basis. IN detail, Banks has determined that for Real Estate Financing loans, the new appraisal will be a Full appraisal, while for other areas, based on the complexity of the transaction, determined by a combination of the type of property being appraised (e.g., shopping center, hotel, industrial plant, etc.), the loan amount, and the age of the appraisal, it may decide whether to proceed with a Drive-by (external inspection) or Desktop appraisal by a reputable appraiser/appraisal company. In other cases, banks realize New full-size valuation report.	See previous answer to point c, first bullet	The reviews for residential properties and agricultural lands are performed mainly using digital tools (AVMs, hybrid methods, etc.). The Reviews for the rest of the collaterals are performed either by desk-top valuations either by a full report with inspection of the collaterals.	#VALUE!	In Spain, the review and revaluation of property valuations are governed by Bank of Spain’s Circular 4/2017, Annex IX, sections 80 to 84. The procedures vary depending on the type of collateral, the classification of the exposure, and the materiality thresholds established by regulation. At the time of loan origination, institutions are required to obtain a full individual valuation report. For performing exposures, if a material decline in value is identified, the valuation must be updated by certified and independent valuation companies, either through a new full individual valuation or, where appropriate, by means of AVMs. Properties other than completed buildings, as well as exposures exceeding EUR 3 million or 5% of the institution’s own funds, must be revalued through full individual valuations at least every three years, or immediately if a significant decline is detected. For exposures under special monitoring, the same rules apply as for performing exposures. However, annual updates are mandatory when the total gross book value of such exposures exceeds EUR 300 million or 10% of the institution’s own funds, or when the gross book value of an individual exposure exceeds EUR 1 million and the loan-to-value ratio is greater than 70%. In these cases, full individual valuations are required, although AVMs may be used exceptionally if the institution can justify their suitability. For non-building collateral and for exposures above EUR 3 million or 5% of own funds, full individual valuations are always required. For exposures classified as non-performing, the reference valuation of the collateral must be updated at the time of classification and at least annually thereafter. Where the collateral consists of completed buildings and the gross exposure is equal to or below EUR 300,000, AVMs may be used provided the properties are suitable for mass valuation models and the institution can justify their appropriateness. However, if the exposure remains in the non-performing category for more than three years, a full individual valuation becomes mandatory. After this point, AVMs and full valuations may be combined, provided that full valuations are carried out at least every three years. For foreclosed assets or those received in lieu of payment, the fair value at the time of acquisition must be based on a full individual valuation report, in accordance with the requirements set out in paragraphs 78 and 79. After acquisition, the reference valuation used to estimate fair value must be updated at least annually, also through full individual valuations. However, if the fair value of the asset is equal to or below EUR 300,000, AVMs may be used provided the properties are suitable for mass valuation models and the institution can justify their use. Once the asset has remained on the balance sheet for three years, a full individual valuation becomes mandatory. After that point, AVMs and full valuations may be combined, provided that full valuations are carried out at least every three years. In estimating the fair value of foreclosed assets, institutions must assess whether a discount should be applied to the reference value due to specific conditions of the asset (e.g. location, physical condition) or market factors (e.g. reduced transaction volume or market activity). This assessment must be informed by the institution’s own sales experience and the average holding period of similar assets. A downward adjustment is also required when the full individual valuation report includes disclaimers or limiting conditions—particularly those arising from the inability to inspect the interior of the property—that have not been reflected in the reference value. In both cases—non-performing exposures and foreclosed assets or assets received in lieu of payment—the valuation company and the professional responsible for the valuation must be changed after two consecutive updates performed by the same company. This requirement applies regardless of the valuation method used (AVM or full individual valuation).	Full-size valuation or desk-top valuation. The monitoring process will make it possible to understand if a review needs to be done.
c) Review of property values and revaluation • For the calculation of average values in accordance with Article 229 (1)(e) CRR in the context of upward revisions of values, are there any guidelines from regulators or lenders addressing the data points to be used and the comparability of properties? Please indicate whether there are requirements from regulators or lenders for ‘sufficient data’ and ‘unequivocal increases of value’.	No, there are no such guidelines.	No		No, the DFSA has not published any interpretations		To date, there are no guidelines from national banking supervisory authorities regarding the average value.	The Hungarian practice follows CRR Article 229(1)(e) strictly: upward revaluation requires averaging at least three comparable data points over 6–8 years and is only allowed if there is unequivocal value increase (e.g., energy efficiency improvements). If sufficient data is missing, upward revision is prohibited except for documented improvements. MNB has not issued separate numeric thresholds but expects banks to define internal comparability criteria and evidence requirements.		No	No, there are not specific criteria stated in the ABI Guidelines The criteria adopted by Intesa Sanpaolo consists of considering a historical series made up a series of data points for commercial/residential properties (one for each year in which we were able to calculate the property’s fair value). Comparability is ensured by the fact that, for each property, the historical series considered refers only to that particular property.	The guidelines that are being used by the banks are the ones from the CRR Directive. Currently there are no additional guidelines received from the national regulator.	no	In Spain, there are no regulatory guidelines, circulars, or valuation standards that address how to calculate average property values for the purpose of Article 229(1)(e) CRR. The concept of “average value” over a six- or eight-year period, as required by the regulation, is not developed or operationalised in any formal framework within the Spanish valuation system. It is important to note that in Spain, independent valuers — namely, valuation companies certified by Bank of Spain — carry out property valuations in accordance with the principle of prudence, as detailed in the responses to section III.a on Property Value.	There are no guidelines published yet. Currently, there are no explicit requirements published by regulators or lenders; however, such requirements may be introduced in the future.
IV. VALUATION OF THE COVER POOL
a) Are valuation rules for cover assets provided at national level in accordance with Article 6(5a) CBD? Are they provided by national covered bond legislation or by professional guidance/standards?	No		The rules are based on Act No. 190/2004 Coll., on Bonds (following the implementation of the EU Covered Bond Directive).	Yes, the valuation rules are entailed in the Dansih Valuation Order issued by the DFSA	France applies a long standing and robust covered bond framework based on obligations foncières issued by specialised credit institutions (sociétés de crédit foncier – SCFs), first established by the Law of 25 June 1999. Framework governing sociétés de crédit foncier (SCF) and obligations foncières, supplemented by prudential supervision from the ACPR. French covered bonds are mainly issued under two dedicated legal frameworks, both embedded in the French Monetary and Financial Code: 1. Sociétés de Crédit Foncier (SCF) : o Can issue covered bonds backed by multiple asset types, including residential mortgages, public-sector loans, and substitute assets. o SCFs issue the well-known “obligations foncières.” 2. Sociétés de Financement de l’Habitat (SFH) o More narrowly focused on residential mortgage loans and substitute assets. o Issue “obligations de financement de l’habitat” (OHs).	Yes, valuation rules are provided by national covered bond legislation in Art. 16 Pfandbrief Act and in the Regulation on the Determination of Mortgage Lending Value (BelWertV).	Hungary transposed the EU Covered Bond Directive (Directive (EU) 2019/2162) through amendments to the Act XXX of 1997 on Mortgage Loan Companies and Mortgage Bonds (Mortgage Bank Act).		At the beginning of 2023, Italy has completed the transposing of the European covered bond legislation, which has become effective from the 31 March 2023. The national legislation is regulated by the Title I-bis of the law n. 130/99 - introduced by the legislative decree n. 190/2021 – and by the secondary disposals of the Bank of Italy which amended the Circular n. 285/2013. The discretion provided for in Article 129(3) of Regulation (EU) 575/2013 (CRR) as amended by Regulation (EU) 2024/1623 (CRR3), for the purpose of valuing immovable property, has not been exercised by the Bank of Italy.	The Italian framework on covered bonds is based on the decree No. 310, of Italian Ministerial of Economy and Finance dated December 14 2006, and the Supervisory Provisions of Banca d’Italia of May 17 2007			Yes. Valuation rules for cover assets are provided in Spain in accordance with Article 6(5a) of the CBD. These rules are established through national legislation, specifically via Royal Decree-Law 24/2021, which transposes Directive (EU) 2019/2162 into Spanish law.	CBD is incorporated in the national law and so is article 6(5).
b) What valuation bases apply for the valuation of cover assets (Market Value, Mortgage Lending Value)?			Market Value	Market value	In the French covered bond framework, while expert valuations are generally performed on a Market Value basis, Mortgage Lending Value (or a prudently filtered long term value) effectively operates as a cap for eligibility and cover tests within the cover pool, ensuring conservatism and long term stability of collateral values backing obligations foncières.	Mortgage Lending Value according to the Regulation on the Determination of Mortgage Lending Value (BelWertV).	Hungarian legislation applies the Market Value principle for the valuation of cover assets in covered bond programs. Valuation must be based on prudent market value, excluding speculative elements or forced-sale assumptions.			Please refer to the section I and II of the Questionnaire; in ISP there is no difference between the rules and the valuation process applied for credit granting (with immovable properties as collateral) and the covered bond cover pool.			In Spain, the valuation of cover assets is based on the Mortgage Lending Value, as established in Article 17 of Royal Decree-Law 24/2021. This requirement is further detailed in Bank of Spain’s Circular 4/2017, Annex IX, section D) “Guarantees and valuations”, which defines the Mortgage Lending Value as the reference value for real estate collateral.	Market Value.
c) In the case of Market Value valuations, are there any prudential or longer term/sustainable features of the property to be considered? If yes, to what extend?			The value is generally more than conservative than MV of the property	The Valuation Order precribes that banks must apply prudent/cautious values, disregard scarcity prices and take a current risk of changes in market conditions or structural changes into consideration.	In France, cover assets are valued on a Market Value basis by independent valuers. However, for inclusion in the cover pool and for regulatory tests, this value is effectively capped by a prudent, long term value reflecting Mortgage Lending Value principles, to limit volatility and ensure conservatism. Any additional prudential buffers or stress adjustments are applied by the issuer at coverpool level, not automatically built into the valuer’s valuation.	not relevant	The Hungarian practice uses Market Value with prudential conservatism. Sustainability features (energy efficiency, ESG) are relevant only for green covered bonds and eligibility criteria, not for the general valuation basis.Long-term aspects are considered indirectly through conservative valuation practices, not as a statutory requirement.			Please refer to the section I and II of the Questionnaire; in ISP there is no difference between the rules and the valuation process applied for credit granting (with immovable properties as collateral) and the covered bond cover pool.			In Spain, the reference value for cover assets is the Mortgage Lending Value, which already incorporates a prudent and long-term perspective. However, if Market Value is used in any context (e.g. for comparison), the regulation requires that speculative elements be excluded and that prudential criteria be applied.	The market valuation shall, by definition, be set as a long-term reliable value. This means that temporary undue fluctuations in a property market and speculative elements must be disregarded.
d) How is the requirement that the valuation shall be carried out by a valuer who possesses the necessary qualifications, ability and experience transposed in your Member State (Article 6(5b) CBD)? Are there specific qualification requirements for valuers?			Act No. 257/2016 Coll., on Consumer Credit	The answer to question 2.2. a) applies.The requirements are the same as for lending based on covered bond funding	Valuations must be carried out by experienced and competent valuers selected on the basis of professional standing and expertise, and they must be independent from loan origination and credit decisions through clear organisational separation.	See 2.1. c)	The Mortgage Bank Act (Act XXX of 1997) and supervisory rules require independent valuers for covered bond-related valuations, compliance with recognized professional standards (e.g., International Valuation Standards (IVS), RICS Red Book) and specific qualifications such as - relevant university degree (real estate, economics, engineering). - professional certification or membership in a recognized body, - demonstrated practical experience in property valuation for financial institutions. There is no separate statutory license for covered bond valuations, but competence is enforced through internal bank policies and Hungarian National Bank supervision			Please refer to the section I and II of the Questionnaire; in ISP there is no difference between the rules and the valuation process applied for credit granting (with immovable properties as collateral) and the covered bond cover pool.			In Spain, Bank of Spain’s Circular 4/2017, specifically Annex IX, section 2.2.1, establishes that valuations must be performed or supervised by certified valuation companies or services registered in the Official Registry of Bank of Spain. The qualifications, ability, and experience are addressed in Royal Decree 775/1997 and have already been covered in the response to question 2.2a (“qualified valuer”).	The valuer must by covered bond law be sufficiently competent and independent. It is the same requirements as for normal mortgage lending.
e) How is the requirement that the valuer shall be independent from the credit decision process transposed in your Member State (Article 6(5c) CBD)?			Act No. 257/2016 Coll., on Consumer Credit	The answer to question 2.2. b) applies. The requirements are the same as for lending based on covered bond funding	Valuations must be carried out by experienced and competent valuers selected on the basis of professional standing and expertise, and they must be independent from loan origination and credit decisions through clear organisational separation.	According to § 7 BelWertV, valuers must be independent of the loan acquisition and loan decision-making process, as well as of property brokerage, sales and rentals. They must not have any family, legal or economic relationship with the borrower and must not have any personal interest in the outcome of their valuation report. Certain concessions apply with regard to independence in the small loan sector pursuant to § 24 BelWertV.	Hungary has transposed the EU requirement that the valuer must be independent from the credit decision process into its national framework. The Mortgage Bank Act (Act XXX of 1997) and supervisory rules require: - valuations for cover assets to be performed by an independent valuer, not involved in loan origination or credit approval. - mortgage banks to implement internal governance procedures ensuring organizational separation between valuation and credit decision-making. Independence is typically achieved by outsourcing valuations to external appraisers or assigning them to internal units that are structurally separate from lending departments. Banks must have documented conflict-of-interest policies and procedures to prevent valuers from participating in credit decisions.			Please refer to the section I and II of the Questionnaire; in ISP there is no difference between the rules and the valuation process applied for credit granting (with immovable properties as collateral) and the covered bond cover pool.			Bank of Spain’s Circular 4/2017, specifically Annex IX, section 2.2.1, requires that valuations be performed or supervised by certified valuation companies or services registered in the Official Registry of Bank of Spain. These entities must be independent from the credit institution. According to the circular, independence is deemed fulfilled when the valuation company is not a related party to the institution, as defined in section 1 of rule 62, and complies with the requirements of the Mortgage Market Law and its implementing regulations. The specific requirement that the valuer be independent from the credit decision process is addressed in Royal Decree 775/1997 and has already been covered in the response to question 2.2b (“independence”).	For an asset to be eligible as a covered asset it must, among other rules, be in line with the requirements in CRR article 129(3), which refer to CRR article 208 that incorporates the requirements of the valuer’s independence.
f) Are there differences in valuation rules and/or qualification requirements with regard to the property type (residential vs. commercial properties) or to the loan amount?			There are differing requirements for valuers. Banks typically keep internal panels (approved lists) of valuers by property category. Residential properties may be valued by less experienced/junior valuers, usually under appropriate supervision. Commercial valuations are allocated to valuers in tiers based on the expected property value—commonly an SME tier up to CZK 100 million, and higher tiers such as Large Corporate or Commercial Real Estate.	The valuation rules and requirements are the same but the lendig limts differs	The same overall rules apply to residential and commercial properties, but commercial or more complex assets are subject in practice to more detailed analysis, closer monitoring and greater prudence (refer to answers done in the previous section).	If a loan can be classified as a small loan within the meaning of § 24 BelWertV (residential property, sum of the land charge and the value of rights and encumbrances is less than EUR 600,000, use for commercial purposes is allowed if the income attributable to this use may not exceed one third of the gross income) and the requirements for the mortgaged property are met, the following reliefs can be claimed: - Documentation of the valuation: Instead of a formal valuation report in accordance with § 5 BelWertV, a so-called simplified valuation is sufficient. Extensive textual explanations, e.g. on the assessment of the location quality or the condition of the property, can be omitted and are replaced by standardised text modules and/or assessments based on a selection from predefined scales. Regardless of this, the value-relevant approaches must be justified, albeit in a simplified form. - Regarding the qualification and independence of valuers: Valuers in the small loan sector must be sufficiently trained and qualified to determine the Mortgage Lending Value of the relevant properties within the small loan limit. Furthermore, the valuer must not be the same person who makes the final credit decision or determines the Mortgage Lending Value. Nor may they have any family, other legal or economic relationship with the borrower, nor may they have any personal interest in the outcome of the valuation. There is no requirement to engage a valuer - who is independent of the credit acquisition and credit decision-making process as well as of property brokerage, sale and letting. In order to ensure the correctness of the valuations, valuers who meet the requirements of §§ 6 and 7 BelWertV must review a sufficiently large and representative sample of valuations at regular intervals. - During the inspection: There are exceptions that justify completely waiving an inspection in the case of small loans and further exceptions in which an interior inspection may be omitted.	Hungarian law does not differentiate qualifications by property type or loan amount.			Please refer to the section I and II of the Questionnaire; in ISP there is no difference between the rules and the valuation process applied for credit granting (with immovable properties as collateral) and the covered bond cover pool.			Yes. As detailed in response 1.2.g, the applicable valuation methods vary depending on the property type, in accordance with the provisions of Order ECO/805/2003. With regard to the loan amount or exposure, section 2.2.2 of Annex IX of Bank of Spain’s Circular 4/2017 introduces thresholds that determine the required frequency of valuation updates, the type of review (full appraisal or AVM), and the admissibility of certain methods.	No
g) Are there specific monitoring, review and revaluation requirements for cover pool assets at national level (see Article 129(3) CRR referring to Article 208 CRR)?			Banks has implemented own internal rules. Generally at least annually for commercial properties and once every three years for residential properties; more frequently in the event of significant market changes.	No	Monitoring, review and revaluation of cover pool assets follow Articles 129 and 208 CRR, with regular checks, more frequent reviews during periods of market stress, and valuation methods proportionate to risk. There is no general allowance for unchecked upward revaluations: any increase in value must be well supported and consistent with maintaining cover pool quality and overcollateralisation.	In addition to Article 208 (3) CRR, § 26 BelWertV also sets out requirements for reviewing Mortgage Lending Values in the context of Pfandbriefe: according to this, a review is required if there are indications that the basis for determining the Mortgage Lending Value has deteriorated to a significant extent. This applies in particular if the general price level on the respective regional property market has fallen to an extent that jeopardises the security of the mortgage. In practice, this requirement can be integrated with the monitoring and review process in the context of Article 208 (3) CRR. Unless owner-occupied residential properties are concerned, a review must also be conducted if the claim secured by the property serving as collateral shows substantial payment arrears of at least 90 days.	Hungarian law requires regular revaluation of cover assets. Valuations must reflect prudent market value, independent valuers must perform valuations and updates etc.			Please refer to pag 6 of the document : https://www.bancaditalia.it/compiti/vigilanza/normativa/consultazioni/2024/2024.12.18-disposizioni-vigilanza/Documento_di_consultazione_18.12.2024.pdf			Yes, Spain has specific monitoring, review and revaluation requirements for cover pool assets, as established in Bank of Spain’s Circular 4/2017, Annex IX, sections 2.2.2 and 2.2.3. Institutions must verify at least once a year whether there are signs of significant declines in the value of real estate collateral classified as performing or under special monitoring. If a material decline is detected, the valuation must be updated by certified and independent valuation companies or services. For exposures exceeding EUR 3 million or 5% of the institution’s own funds, valuations must be updated at least every three years, even in the absence of a decline. For non-performing exposures, the valuation must be updated at the time of classification and at least annually thereafter. Additionally, the valuation company or professional must be rotated after two consecutive valuations.	No
h) Do regulators of your Member State provide a waiver from the limitation of calculating average values for cover assets in case of upward revision of values (Article 129(3) second subpar. CRR)?			The CNB issued a measure of a general nature (January 2025) allowing, under specified conditions, an exemption from the “averaging” limitation under Article 129(3) CRR for covered bonds	Yes		The national banking supervisory authority BaFin exercises the option under Article 129(3)(2) not to apply the cap under Article 229(1)(e) CRR. Mortgage Lending Value increases are generally not permitted. In practice, there are two exceptions: Value increases are permissible if they result from a revaluation of the mortgage lending value, provided that structural alterations are made to a property which significantly exceed of the value. Furthermore, value increases are possible in the case of new credit decisions.	The Hungarian regulator has not introduced a waiver related to Article 129(3) second subparagraph of the CRR concerning the calculation of average property values for cover assets.			https://www.bancaditalia.it/compiti/vigilanza/normativa/archivio-norme/circolari/c285/aggiornamenti/Circ-285-Testo-integrale-al-50-aggto.pdf https://www.bancaditalia.it/compiti/vigilanza/normativa/consultazioni/2024/2024.12.18-disposizioni-vigilanza/Documento_di_consultazione_18.12.2024.pdf			No, in Spain there is no waiver because the limitation referred to in Article 129(3) second subparagraph of the CRR is no longer present in the latest consolidated version of the Regulation. The current text does not include any restriction on taking into account upward revisions of property values in the calculation of the average value of cover assets.	Yes
V. OTHER
REGULATORY HARMONISATION AND NATIONAL DIVERGENCES
1. What challenges does your Member State face in harmonising with EU regulations (e.g. legal, technical, market-related)?	Legal and Market related			Not aware of the challenges faced by the individual banks	France is broadly compliant with EU valuation rules, but full harmonisation is constrained by legal, technical, and market specific factors. The main challenge lies in adapting traditional French market value based valuation practices to the EU’s newer prudently conservative “property value” concept under CRR3, which creates uncertainty over methodology, documentation, and the division of responsibility between valuers and banks. Methodological differences persist, as France relies heavily on notarial transaction data, while EU supervisors seek greater cross border comparability for prudential purposes.	Valuation practices in Germany differ from those in other jurisdictions. These differences relate to both technical details and the legal and institutional framework. The so-called Anglo-Saxon methods and international approaches, which are widely used elsewhere in Europe and are largely driven by the requirements of the EVS, IVS and Red Book, are only used to a limited extent in Germany. National requirements prevail. Organisational peculiarities such as the widespread reliance on internal Valuers are also unique to Germany. In applying EU regulations and in ECB supervision practice it is therefore very challenging to raise awareness of these peculiarities in German valuation practice and to emphasise that a different approach is not necessarily inferior, but can also meet the requirements.	Hungary has successfully implemented the EU framework, but faces legal interpretation issues, technical compliance costs, and market structure limitations.			Italy has made progress in aligning with EU valuation and financial regulations. However, challenges remain in legal uniformity, technical harmonisation, and market transparency. Overcoming these issues will require stronger national coordination and continued alignment of valuation methodologies with evolving EVS, IVS, and EU prudential standards.		1. With regard to "prudential value," nothing is defined in international real estate valuation standards, so it does not exist as a type of valuation. 2. Regarding the calculation of ETV in cases where a bank has secured a loan with multiple properties with different mortgage ranks, is ETV calculated at the loan level? 3. At the national level, there is no calculation of a significant deviation in the real estate market that would be mandatory for all banks, and there are no instructions on how to proceed - to revalue real estate in this case.	Spain does not face significant challenges in aligning its property valuation framework with EU regulations. On the contrary, Spain has been a pioneer in applying the concept of “property value” — understood as mortgage lending value — and the principle of prudence since 2003, through the national regulation Order ECO/805/2003. These principles are now being promoted across the EU, but have long been embedded in the Spanish system. The Spanish valuation framework is robust and well-established, built around certified valuation companies supervised by Bank of Spain. These companies combine strong technical, human, and technological capabilities with on-the-ground valuers who have deep knowledge of local markets. This structure ensures consistency, reliability, and prudence in valuations, and provides a high level of resilience and transparency.	All standards and regulations always need to be nationalised and interpreted locally. Sometimes will national legislation or regulations have other meanings but normally will it be compliant to EU regulations after some adjustments. Every country has specific conditions and prerequisites which can be complicate to adapt to the regulation.
DATA QUALITY, TRANSPARENCY AND COMPARABILITY
a) What data sources are typically used by valuers in your Member State, and to what extent do they comply with Article 208(3a) of the CRR?	Usually, asking prices with specific adjustments and actual transaction prices, where such information is available.	In Croatia, there is a central information system for the real estate market called eNekretnine (managed by the Ministry of Physical Planning, Construction and State Assets), which enables the collection and sharing of data on real estate transactions — purchase prices, types of properties, locations, etc.		Public registers are the main data source to ensure compliance with Article 208(3a) of the CRR.	In France, valuers typically rely on a combination of official notarial transaction databases and professional market sources. DVF (Demandes de Valeurs Foncières) database, published by the tax authorities : historical transaction prices for residential and land. Notarial databases: PERVAL and BIENS. Valuers primarily use the Notaries' databases (BIEN/PERVAL) and the government's DVF (Demande de Valeurs Foncières) open data for transaction transparency.	For Monitoring see question IIIb. For valuation purposes: The information on local property markets derived from the purchase price collection by the valuation boards (“Gutachterausschuss”) is a valuable aid in the valuation of properties. Due to their excellent regional and local knowledge, the valuation boards and their offices can often provide information on local conditions or special features of the property market. In addition, there are both cross-bank databases of banking associations and numerous database initiatives by private providers.	We consider it extremely important to use accurate and well-documented data when preparing property valuations. A real, official database of comparable sales transactions is available for valuations. In addition, data from major real estate listing portals is also commonly used. Furthermore, official construction costs are calculated based on an engineering publication issued annually. Statistical data is sourced from the Central Statistical Office and from publicly accessible or subscription-based or paid databases.		Valuers use a broad mix of public, private, and field data sources, ensuring comprehensive, verifiable, and independent information: • Official and Public Data Sources: Land Registry (Catasto), “Conservatoria dei Registri immobiliari” and OMI database from “Agenzia delle Entrate”; ISTAT (italian National Statistics Institute; • Private Data sources: (i.e. Idealista, Immobiliare.it, Nomisma, Scenari Immobiliari) As far as it concerns the Energy and building registries (i.e. Energy Performance Certificate (EPC) databases) data do not have always fully open access are not collected or accessible through a single, national-level database	Valuers use a broad mix of public, private, and field data sources, ensuring comprehensive, verifiable, and independent information: • Official and Public Data Sources: Land Registry (Catasto), Conservatoria dei Registri immobiliari and OMI database from “Agenzia delle Entrate”; ISTAT (Italina National Statistics Institute; • Private Data sources: (i.e. Idealista, Immobiliare.it, Nomisma, Scenari Immobiliari As far as it concerns the Energy and building registries (i.e. APE databases) data do not have always fully open access are not collected or accessible through a single, national-level database.		Monitoring through models and internal individual revaluation, full valuations for secured lending remain the responsibility of professionally competent and independent valuers.In Slovenia typically used data sources (Public Registers and Official Records): Land Registry (Zemljiška knjiga) for ownership and legal status, Surveying and Mapping Authority (GURS) for property characteristics and cadastral data, Transaction databases ETN (Evidenca trga nepremičnin) for historical sales prices and statistical data available on SURS (Statistical Office of the Republic of Slovenia), GURS reports on the Slovenian real estate market. Market Data: Real estate listings and transaction evidence from agencies and portals	In Spain, the monitoring of property values is primarily carried out through periodic valuations commissioned by financial institutions and conducted by certified valuation companies supervised by Bank of Spain. These companies are responsible for applying prudent and traceable methodologies and for managing the data sources used in the process. Valuations are based on verified and consistent information, including internal databases built over years of market activity, physical inspections by qualified professionals, public records (such as the Land Registry and Cadastre), curated data from real estate portals, and direct observation of local market conditions.	Data is to a large extent sourced from public registers. Banks must show compliance to 208 (a) on an individual basis.
b) What measures have been taken to improve transparency and comparability of valuation data within your Member State?	N/A	None as far as we know		The Banks valuation data are not shared and will probably not be shared in the future. Some private data providers collects information on rents in new contracts and collects sales prospectuses and compares the data with the final sales price to calculate the yield. Banks purchases access to these databases to enable better valuation of commercial property.	The DVF helps in that regard.	All of the players mentioned under a) – valuation boards, association initiatives and private providers – are continuously developing their databases with the aim of providing up-to-date and granular data for many types of property, thereby contributing to quality development in property valuation.	Hungary has improved transparency and comparability through national bank's regular housing market reports and mandatory data reporting, adoption of international valuation standards and ESG data integration.	There are statutory Commercial Lease and Residential Property Price Registers through which property transaction information can be viewed at www.psr.ie	Currently, the valuation data are fragmented and not fully open accessible.	Currently, the valuation data are fragmented and not fully open accessible.		Slovenia introduced a mass appraisal system based on standardized models and official market data. All valuations are stored in a central database, accessible to the public via the eProstor portal, ensuring transparency and consistency across the country. Citizens can check valuation models, property characteristics, and estimated values online. The system allows comparisons between similar properties, improving market transparency. Data on transactions concluded on the real estate market, property transaction data source is the Real Estate Transactions Database (ETN), kept by the Surveying and Mapping Authority of the Republic of Slovenia (GURS), reporting is scheduled until the 15th day of the month in which the deal was concluded. According to the rules, all deals that were concluded with real estate last month should be reported already in the next month.In practice, it turns out that only a share of transactions concluded in the previous month is reported by the 15th of the current month, while part of the data is reported with a delay. GURS transmits real estate transaction data to the Statistical Office of the Republic of Slovenia (SORS) no later than 65 days after each transaction.	The recent Order ECM/599/2025, which amends Order ECO/805/2003, has introduced significant improvements in the traceability, transparency, and comparability of data used in property valuations. Valuation companies are now required to document the sources of the relevant characteristics of the comparables used and to justify the traceability and consistency of those characteristics. They must also provide a reasoned explanation of the variables selected for the adjustment process, demonstrating that these are the key drivers of value, and describe the methodology and metrics used to determine the adjustment coefficients. If weights are assigned to comparables, the rationale and specific weighting must be explicitly justified. When a surface area other than the verified usable area is used in the adjustment process, a coefficient must be included to reflect the impact of the difference between the adopted surface and the usable area in both the subject property and the comparables. In addition, the source of each comparable must be disclosed, along with whether it was visited, and all relevant information must be provided — especially regarding the variables used in the adjustment process. The comparables must also include the cadastral reference, the relevant surface areas used in the valuation (at a minimum, the usable area or the constructed area excluding common elements, and the one adopted for valuation, if different), along with their respective sources. Finally, both the asking price and the adjusted price used in the valuation must be reported, including a description of the individualised analysis conducted to derive the latter from the former, explicitly detailing components such as negotiation discounts, brokerage commissions, and other relevant factors.	N/A
c) Is there a central database or platform for sharing valuation data in your Member State?	NO			No	There is not a single and central database platform combining all data. However, DVF is a national reference (for residential and lands only).	No	No, there isn't.	As above. There is no central database covering all asset types.	No, there is not a central database for sharing valuation data.	No, there is not a central database for sharing valuation data.		Slovenia introduced a mass appraisal system based on standardized models and official market data. All valuations are stored in a central database, accessible to the public via the eProstor portal.	Certified valuation companies act as de facto data hubs. Each company maintains its own internal databases, built from years of market activity, field inspections, and verified transactions. These databases are not shared across entities or with external platforms, but they serve as the backbone of the valuation process, ensuring consistency, traceability, and technical depth.	No
EDUCATION, TALENT PIPELINE AND PROFESSIONAL DEVELOPMENT
a) What training programs or continuing education opportunities are available for property valuers in your Member State?	According to the National Valuation Act, each valuer must complete CPD—5 hours annually for each specialty. These CPDs are monitored by the Ethics Committee and are mandatory data in the annual report to CIAB.	In the Republic of Croatia, various training programmes and continuing education opportunities are available for real estate valuers. Some of them are: • Croatian Institute of Finance (HIF) – offers preparatory courses for certified valuers, including both theoretical and practical modules followed by a final examination. • Baltazar University of Applied Sciences – provides a professional development programme in “Real Estate Management and Valuation,” offering multidisciplinary knowledge in law, economics, construction, and valuation. • Croatian Valuers Association (HDP) – a professional association that organises training sessions, workshops, and certification exams for property valuers. • Croatian Association of Court Experts and Valuers (HDSVIP) – organises seminars, congresses, and professional lectures for its members and other court experts and valuers. These programmes enable valuers to pursue continuous professional development and stay up to date with new regulations, methodologies, and market practices in the field of real estate valuation.		Courses and traning will primarily be undertaken by the banks themselves. Furthermore, several specific cources are provided by The Danish Association of Real Estate Agents and the Danish Asssociation og Investment Property Owners	There are events, trainings organized by several real estate associations, professional bodies, universities, etc. In France, for everyone working in real estate, 14h CPD are mandatory per year.	The academies of the banking associations in Germany offer training programmes specifically for valuers for lending purposes to prepare them for the HypZert certification examination (see question 2.1.). In addition, there are numerous training and further education programmes offered by private providers.	In Hungary, real estate valuation can be studied through the following programs: state-accredited real estate brokerage and valuation training; state-accredited advanced real estate asset valuation training; and, within university adult education, the real estate manager program is available. In addition to these, the Hungarian Real Estate Association accredits Advanced Real Estate Valuation qualifications (EUFIM). RICS accreditation (MRICS/FRICS/AssocRICS) is also available.	CPD and training are available from the Society of Chartered Surveyors Ireland for Registered Valuers in Ireland. Training is also available through RICS.	There are different training programs and continuing education programs, mainly proposed by organizations, private entities, professional bodies.	There are different training programs and continuing education programs, mainly proposed by organizations, private entities, professional bodies.		Following conditions must be met for the licence of ceritied appraiser: completed at least a second level study programme, minimum of five years of work experience in a field requiring the knowledge to carry out the tasks of a certified appraiser of the property , passed examination of professional competence, an appraiser has not had a licence for carrying out the tasks of a certified appraiser withdrawn in the past and has not been convicted of a crime against property or an economic crime that has yet to be expunged from the record and has a high level of active knowledge of the Slovenian language. Renewal of the license for certified property valuers (ZRev) in Slovenia; Validity: The license is valid for 3 years from the date of issue. Conditions for renewal: The holder must prove continuous professional education: At least 60% of the required hours must come from participation in workshops, seminars, and conferences organized by the Slovenian Institute of Auditors or by publishing professional articles. The remaining hours can be obtained through other forms of education (e.g., lectures by other providers, postgraduate studies, reading professional literature). The renewal request must be submitted before the license expires. If conditions are met, the validity continues until the decision is made. Failure to renew: If the license expires and is not renewed, the person is removed from the register of certified valuers.	Please refer to 7(b)	None particular but there are several different types of professional courses supported by Samhällsbyggarna and RICS.
b) Is there collaboration between universities, professional bodies, and regulators to ensure a sustainable pipeline of qualified valuers?	Yes, CIAB has agreements with all major universities.			To some extent there is collaboration between universities and banks to ensure qualified valuers		Yes, except of regulators. One example is the dual degree programme in property valuation offered by Anhalt University of Applied Sciences in cooperation with HypZert and numerous industry partners such as banks and valuation companies. https://www.hypzert.de/de/duales_studium	We maintain collaborations with professional associations and governmental institutions; however, there is considerable potential for further development in this area.	There is collaboration between professional bodies and universities to ensure a sustainable level of new entrants to the sector. Recent SCSI research, available at https://scsi.ie/employment-outlook-for-the-surveying-profession-2026-2029/ highlights future surveying needs and opportunities.	Yes, there is collaboration between universities, professional bodies and regulators to assure a pipeline of qualified valuers, with mandatory training courses and certifications	Yes, there is collaboration between universities, professional bodies and regulators to assure a pipeline of qualified valuers, with mandatory training courses and certifications		The University of Ljubljana (Faculty of Civil and Geodetic Engineering) and the University of Maribor offer programs in real estate valuation, geodesy, and municipal economics. These programs provide the academic foundation for future valuers and include topics such as market analysis, valuation methodologies, and legal frameworks. Professional Bodies, The Slovenian Institute of Auditors and the Association of Sworn Valuers and Experts in Civil Engineering organize specialized courses, workshops, and certification programs for valuers. They also set standards for continuing education and collaborate with universities to align curricula with professional requirements.	Yes, there is collaboration between universities, professional bodies, and regulators to ensure adequate and sustainable training for valuers in Spain. Above all, the Bank of Spain oversees compliance with Royal Decree 775/1997, which defines as qualified professionals those who are architects, technical architects, or building engineers when valuing urban properties in all cases, or plots and buildings intended for residential use; and engineers or technical engineers with the relevant specialization, depending on the nature of the asset being valued, in all other cases. By establishing these professional profiles, the Bank of Spain effectively requires a specialized university degree as a guarantee of technically qualified valuers. In addition, joint training initiatives are developed between sector associations and academic institutions. A notable example is the collaboration between AEV and the Fundación Escuela de Edificación (FEE) in the International Asset Valuation course, delivered by the Colegio de Aparejadores de Madrid, which incorporates international standards and specialized instruction. Technical seminars are also organized by entities such as IVSC, allowing professionals to stay up to date with global methodologies and regulations. Furthermore, various valuation companies collaborate with universities through specialized training programs and courses. Some of these entities have participated in academic activities with the Universitat Politècnica de València, which hosts a research center dedicated to valuation.	Yes there are a combination of different educations and courses to ensure the pipeline of qualified valuers.
c) How does the EU regulatory environment influence the development and attractiveness of the valuation profession?	CIAB is recognized as an AMA organization and holds membership in TEGOVA.	The Law on Real Estate Valuation, adopted in line with the European Union regulatory framework, promotes the application of reliable and harmonised valuation standards, independence and professional competence of valuers, and a stronger link between valuation practices, risk management, and sustainability. As a result, the profession has become more structured, transparent, and professional, which enhances its credibility and attractiveness in both the domestic and European markets.		The regulatory requirements might affect recuitement adversely	Complicated question to answer as I need to give you the big picture of France.	Due to increased regulatory requirements in property valuation, particularly at EU level, the demands placed on valuers are growing continuously.	On one hand, we believe that processes are becoming more efficient and standardized, which is highly positive; however, in many cases, they tend to become overly bureaucratic and more complex. In Hungary, at banking property valuations, the recommendations of EVS, IVS, and the Red Book also can be followed. Additionally, the Hungarian National Bank periodically updates its detailed guidelines on real estate valuation, which also take EU requirements into account.	The attractiveness of the profession can be enhanced through EU regulation that promotes higher professional standards and, in turn, recognises the important role of valuers in the built and natural environment.	Currently there is no clear evidence (supported by data, survey) of any positive or negative effect of the EU regulatory on the development of the valuation process or the attractiveness of the valuator profession	Currently there is no clear evidence (supported by data, survey) of any positive or negative effect of the EU regulatory on the development of the valuation process or the attractiveness of the valuator profession		We see the EU regulatory environment makes the valuation profession more structured and credible by enforcing harmonized standards (EVS, IVS), strict compliance rules under directives and transparency requirements. It also introduces ESG and sustainability criteria, creating new opportunities for specialized valuers.	In the case of Spain, the impact of the EU regulatory environment on the development and attractiveness of the valuation profession has been limited in structural terms, as Order ECO/805/2003 had already incorporated advanced technical criteria such as the concept of property value before its consolidation at the European level. However, new EU requirements related to sustainability, traceability, and transparency are introducing elements that may help the valuation practice evolve. These requirements are driving a shift toward greater process digitalization and the integration of climate and environmental criteria into valuation reports. This transformation demands not only the development of advanced technological solutions—which only valuation companies are well positioned to deliver—but also an expansion of technical and digital competencies among valuers. In this sense, the European regulatory framework is contributing to a redefinition of the professional profile of the valuer, making it more demanding and specialized.	In a negative way.
FUTURE TECHNOLOGICAL AND REGULATORY DIRECTIONS
1. What technological developments are expected to impact valuation processes in your Member State over the next five years?	AI and AVM	In the next five years, an increase in the use of automation and digitalisation in property valuation processes is expected, particularly through the development and application of AI technologies and AVMs.		The continuing improvement of databases, including databasess on yields and rents, and the technical developments, including the use of AI, will affect the valuation processes.	Balancing strict ESG requirements with market liquidity and the cost of frequent revaluations, and consistency of data. The other direction is the one related to Digital Assets and Tokenisation.	The continuous expansion of databases for maximum transparency and the technical possibilities of AI are the main drivers influencing the work of valuers and the professional field of property valuation.	The future of the real estate valuation profession will be shaped by the rapid advancement of data science and geospatial technologies, the integration of AI-driven solutions into our processes, the evolution of drone and laser technologies, and increasingly efficient communication.	AI	In the next five year, potential impacts on the valuation process could by due to the progressive development, expansion and exploitation of the A.I applications, specific for the real estate sector. In parallel the expansion and exploitation of the BIM Building Information Modeling application could improve data availability and transparency.	In the next five year, potential impacts on the valuation process could by due to the progressive development, expansion and exploitation of the A.I applications, specific for the real estate sector; in parallel the expansion and exploitation of the BIM application could improve data availability and transparency.		Expected technological advancements include: • Advanced Automated Valuation Models (AVMs) – initially for quality control and pre-preparation of valuation opinions. • Computer Vision – for analyzing photos, satellite imagery, property access, and legal status from land registries, enabling monitoring of property changes. • Integration of ESG Criteria – where AI evaluates energy efficiency and sustainability parameters based on public data and predefined benchmarks. • Generative AI for Report Preparation – reducing administrative workload and speeding up the processing of loan applications.	Over the next five years, Spain is expected to see significant technological developments in the valuation sector. These innovations will be integrated within a prudential and regulated framework, where independent valuation companies remain central to the process. AVMs and artificial intelligence are likely to play a growing role in supporting valuation processes, particularly in areas such as portfolio monitoring, market analysis, and anomaly detection. However, in Spain, these technologies are understood strictly as tools that assist — but do not replace — the professional judgment of the valuer. This approach is fully aligned with the position expressed in the July 2025 IVS paper Navigating the Rise of AI in Valuation, which emphasises that AVMs and AI must remain subordinate to human expertise and embedded within a structured, transparent valuation process. In the context of mortgage lending, AVMs are not used as standalone valuation methods, but rather as complementary instruments that enhance the efficiency and consistency of the valuer’s work, always under the principle of prudence. Following the recent update to Order ECO/805/2003, which incorporated environmental and climate-related criteria into valuation reports, it is expected that additional ESG dimensions — such as social and governance factors — will be progressively integrated. This will require new data sources, analytical tools, and reporting standards, all of which must be adapted to the prudential framework and supervised valuation model in Spain. Technological advances will also continue to improve document management, traceability, and interoperability between valuation companies, financial institutions, and regulators. Platforms that ensure secure data exchange, auditability, and process transparency will play a key role in strengthening the reliability and efficiency of the valuation ecosystem.	All technologies such as Artificiell Intilligence will affect the processes to perform property valuations. It will be a continued technical development towards simplifications and improved valuation models. Different databases for property information and property valuation will enable further possibilities and quality assurance.