Response to discussion on Technical Advice on selected KPIs under the Taxonomy Disclosures Delegated Act under Article 8 of the Taxonomy Regulation

Q1. Please identify your organisation (if applicable) and indicate the capacity in which you are responding to this consultation:

Q2. Do you agree with the analysis presented?

WWF position: Partially — the mapping is right, the 'limited relevance' conclusion is not. 

WWF agrees with the four-service mapping. But being flow-based is the KPI's function, not its flaw: the GAR captures the stock of lending and structurally misses banks whose sustainability impact runs through deal facilitation. Deleting this KPI would make the most capital markets-intensive banks the least transparent under Article 8. Volatility is handled by multi-year presentation, as for any flow metric; the confidentiality risk can be addressed: it is confined to thin deal volumes, is managed by the 10% threshold and aggregation, and shrinks as EuGBS issuance grows. Finally, paragraph 35 is circular: the EBA proposes to delete the FINREP datapoints and then cites prospective data unavailability against the KPI — supervisory reporting should follow the disclosure decision, not pre-empt it. 

In your response, where applicable, please assess whether voluntary disclosure of this KPI would be meaningful and feasible, and hence should be considered.

WWF position: Option (b) — mandatory, narrowed, with the 10% threshold. 

This is real simplification (only ~16% of institutions would exceed the threshold, i.e. very few) while keeping disclosure exactly where it matters: the large capital-markets banks. WWF opposes option (a): qualitative-only 'composition, trends, objectives and policy' text is not comparable, likely not auditable, and invites narrative greenwashing without a quantitative anchor. Voluntary disclosure is no substitute — leaders disclose, laggards abstain, comparability collapses. WWF also asks the EBA to retain the four relevant FINREP 22.1 datapoints in the parallel ITS revision, so the narrowed KPI costs preparers nothing extra. 

Q4. Should additional items from FINREP Template 22.1 also be included in the revised KPI? Please consider in particular that (i) have been assessed as unrelated to capital market activities, e.g. ‘custody and other related services’, and (ii) those that have not been mapped to the Fees and Commissions KPI, such as ‘structured finance’, ‘loans granted’, ‘commodities’.

WWF position: Assess structured finance; keep the transactional services out. 

Green securitisation and green ABS have a direct use-of-proceeds link to aligned assets and will grow under the securitisation review and the EuGBS — structured finance therefore merits assessment for inclusion. Custody, payments, clearing and FX are rightly excluded as transactional; 'loans granted' belongs analytically to the GAR. 

Q5. Do you have evidence and/or arguments on potential costs and benefits associated with disclosing the Fees and Commissions KPI?

WWF position: Costs are front-loaded and shared; benefits grow with green issuance. 

The FINREP mapping exists and the counterparty alignment data is the same data that banks must obtain for the GAR — the marginal cost of the narrowed KPI is modest. The benefit scales up with green issuance volumes, so a cost-benefit test anchored to 2026 volumes structurally understates the steady-state value; a KPI deleted now would likely have to be rebuilt later at higher cost. It is also the only instrument allowing users to compare investment banking franchises on their contribution to sustainable capital flows. 

Q6.Do you agree with the analysis presented?

WWF position: Partially — fair description, wrong conclusion. 

The descriptive points are fair, but the test applied is again 'is this the GAR?'. The KPI's job is different: to give visibility on whether a EUR 5 trillion asset class supports the market for sustainable instruments. Leaving it with zero quantitative Article 8 coverage is a blind spot, not proportionality. And paragraph 66 inverts its own logic: that market making is only one liquidity channel argues for precise labelling of a narrower KPI, not for abandoning quantitative disclosure altogether. 

In your response, where applicable, please assess whether voluntary disclosure of this KPI would be meaningful and feasible, and hence should be considered.

WWF position: Option (b), strengthened — a mandatory Market-Making KPI for Taxonomy-aligned securities. 

The positive case, in four steps: 

• Liquidity comes first. Investors buy green bonds and green issuers' shares at issuance only if they can trade them afterwards. Dealers' commitment to quote aligned instruments directly conditions the cost of green capital and the scale-up of the EU Green Bond Standard. This is the single most policy-relevant slice of the trading book — exactly the enabling function the Commission's Call for Advice identifies.
• The scope is documented and auditable. Market making runs on written agreements with trading venues (RTS (EU) 2017/578), so the covered instruments are known in advance and stable. This answers the EBA's operational objection (para 61): no trade-by-trade assessment across the whole book — only a finite, contract-defined instrument list, assessed with the same issuer data the bank already needs for the GAR.
• A ratio design removes the noise. Construct the KPI as aligned instruments under market-making agreements over all instruments under such agreements. Numerator and denominator move with the same market conditions, so the 'external market factors' the EBA worries about (para 60) largely cancel out — what remains is the bank's own choice of what it commits to make markets in.
• Do not shrink it to bonds only. Equity liquidity matters most for smaller pure-play green issuers. Scope should be all aligned debt and equity under market-making agreements, with a mandatory sub-line for European Green Bonds (trivially identifiable at ISIN level). Qualitative disclosures (Annex XI) should complement, not replace the KPI. 

Q8. Do you have evidence and/or arguments on potential costs and benefits associated with disclosing the Trading Book KPI?

WWF position: The market-making redesign is cheap; the information exists nowhere else. 

The instrument universe under market-making agreements is small and stable relative to the full trading book; alignment data is reused from the GAR; volume infrastructure already exists via the Basel G-SIB reporting the current KPI is modelled on. The benefit: the only standardised indicator of banks' contribution to secondary-market liquidity for sustainable instruments — increasingly valuable as the stock of aligned and EuGBS instruments grows.  

Q9. Do you agree with the analysis presented and the conclusion to narrow down the investment firms’ KPI?

WWF position: Yes. 

The four retained services are exactly those where the firm exercises discretion or influence over where capital goes; the excluded services are client-driven and administrative. No decision-useful information is lost. 

Please explain if you think that other services, e.g. execution of orders on behalf of clients, should be included in the revised KPI.

WWF position: Yes — and keep execution of orders out. 

Execution is client-driven; adding it back would dilute the KPI with flows the firm does not allocate. Discretionary situations resembling order handling are already captured under portfolio management. 

Q11. Do you consider it more appropriate for the KPI to reflect the value of assets covered by the investment services rather than the monetary benefits generated?

WWF position: Yes — with three conditions. 

An asset-based measure is more stable, insensitive to pricing structures, and comparable across the three fiduciary KPIs — the same 'one method for managed assets' point WWF makes to ESMA (Q23 in ESMA public consultation). Conditions: (i) discretionary and advisory assets reported as separate lines, since the firm's influence differs; (ii) the weighting methodology fully aligned with the asset managers' template; (iii) for underwriting/placing — flow activities with no asset stock — capture the value of instruments placed during the period, so the primary-market facilitation role is not lost in the redesign. 

Q12. Do you agree with the analysis presented and the conclusion to align the grandfathering rules with the approach set out in EU Green Bond Regulation?

WWF position: Qualified agreement — consistency yes, loosening no. 

Cross-framework consistency is valuable, but the EBA should say plainly that seven years instead of five extends the time exposures count as aligned against outdated criteria. WWF supports alignment only as a package: (i) the EuGBS Article 8(3) transparency duties — a published alignment plan with external review — become mandatory in the DDA, not discretionary; (ii) the EuGBS's unlimited grandfathering of already-allocated proceeds is not imported — convergence should be on the stricter current DDA reading (para 88), which caps both; (iii) a dedicated, digitally tagged disclosure line shows the share of each KPI numerator relying on grandfathered criteria, so users can discount stale alignment and track its run-off. That one line converts grandfathering from an invisible integrity risk into usable information at negligible cost. 

Q13. Do you agree with the analysis presented and proposed conclusions?

WWF position: Yes: users need retrievability, not a blend. 

Averaging a bank's GAR with other businesses' KPIs produces a number with no economic meaning, and the para 114 double-counting point is technically correct. What users need is (i) the group KPI under the parent's rulebook, (ii) separately identifiable, digitally tagged KPIs for the materially different businesses, and (iii) machine-readable access — then any user builds whatever aggregation suits their purpose. Simplified subsidiary templates are acceptable if standardised (one Commission-specified format) and tagged, so 'lighter' does not become 'non-comparable'. 

i. Should the KPI disclosed by the parent undertaking, reflecting the group’s main or prevalent activity, be used? If not, what alternative methodology should be applied?

WWF position: Yes, on one condition.

Agree, as in WWF's ESMA response (Q10 there): downstream rules that need one figure should take the parent-rulebook KPI — a synthetic aggregate would recreate the weighted-average problem. Condition: the KPIs of materially different subsidiaries remain separately disclosed and tagged, so an institution financing a specific subsidiary can use the KPI that describes what it finances.  

ii. In the case of a credit institution-led group, such as a financial conglomerate, should the consolidated KPI disclosed by the parent undertaking also incorporate the assets of the insurance (and non-financial) undertaking, rather than accounting for the insurance (and non-financial) undertaking solely through the equity method? Please justify your answer in terms of feasibility, usability and transparency of sustainability information.

WWF position: No — keep the equity method. 

Folding insurance assets into the GAR would break the link with prudential consolidation on which the GAR's verifiability rests and would blend incomparable methodologies. Transparency on the insurance business is better served by the subsidiary's own insurance-template disclosures, cross-referenced from the group report. 

Q15. Which KPIs you do think are necessary and should be required for groups with mixed activities where the credit institution is the parent company such as credit institution-led financial conglomerates, credit institution-led financial holding companies and relevant mixed financial holding companies?

WWF position: Parent GAR + off-balance-sheet AuM KPI, plus tagged subsidiary KPIs above a cumulative 10% threshold. 

At parent level: the GAR and the off-balance-sheet AuM KPI. From material subsidiaries: the investment-firm KPI, the insurance underwriting and investment KPIs, and the asset-manager KPI (ideally on the merged template, Q17), each at subsidiary level and cross-referenced. The 10% trigger should carry the same safeguards WWF sets out to ESMA (Q12 there): expressed as cumulative across all 'other' businesses with an anti-fragmentation clause; below-threshold groups still disclose the nature and turnover share of those businesses, tagged; and for financial subsidiaries a supplementary total-assets test, since their economic weight can far exceed their turnover share. 

Q16. Do you agree with the analysis presented and the conclusion that OpEx financing should not be explicitly incorporated in the methodology for calculating financial undertakings’ KPIs? Please provide your rationale for supporting the explicit inclusion of provisions allowing financial undertakings, on a voluntary basis, to use the OpEx KPI disclosed by their counterparties when calculating their own KPIs.

WWF position: Disagree with the blanket 'no' — support the voluntary option with every transparency disclosure mandatory (same answer as to ESMA). 

For companies whose green performance lives in their operating costs — the rail/grid/water/forestry/fleet family — a ratio built on CapEx alone structurally understates how green the financing is; the EBA's own Box 5 (18% vs 32%) shows the size of the gap. Allowing the voluntary blend closes a real measurement gap, including for working-capital lending to already-aligned operations. The EBA's comparability and greenwashing concerns are answered by conditions, not prohibition: 

• the three disclosures are a mandatory condition of use — whether the blend is used, the CapEx/OpEx split inside the blended figure, and confirmation of consistent application across the whole book — each digitally tagged, so a blended GAR can never quietly inflate reported alignment;
• only company-reported OpEx KPIs may be used — never estimates produced by the bank or a data vendor;
• the option, its conditions and its disclosures must be identical across the EBA, EIOPA and ESMA frameworks, so one company's OpEx is treated the same way in a bank's GAR, an insurer's investment KPI and an asset manager's portfolio KPI;
• usefulness is contingent on ESMA's redesign of the OpEx KPI itself — WWF's proposal there (a two-part mandatory KPI: R&D for all, plus operation/maintenance of aligned assets for a fixed high-relevance activity list) is what makes the input meaningful; the voluntary-use provision should enter into application together with that reform. 

Where a bank uses the blended figure, the digital tag should link the portfolio-level number back to the underlying company KPI so any user can trace and recompute it — the KPI-to-KPI connection the central digital tool proposed under Q19 would make automatic. 

Q17. Should the credit institution’s AuM KPI (Annex V) and the KPI for asset managers (Annex II) be merged? Please explain why and how, including the content of the information that should be retained in a potential merged KPI.

WWF position: Yes — identical to WWF's suggestion to ESMA (Q23.1 there). 

The activity is identical, so the method — ideally the template too, with an entity-type identifier — should be one and the same. The merged methodology should also be the reference for the AuM-based redesign of the investment-firm KPI (Q11), so all three fiduciary KPIs converge on one method. 

Q18. What are your views on the design of off-balance sheet item reflecting financial guarantees to financial and non-financial undertakings in a potential merging of the asset management activities as presented?

WWF position: Keep guarantees separate — split the composite KPI in two. 

Financial guarantees are credit substitutes, functionally closer to lending than to asset management; folding them into an AuM figure would obscure a distinct impact channel. If the merger proceeds, split the composite off-balance-sheet KPI into a FinGuar KPI and an AuM KPI, each with its own numerator and denominator. 

Q19. Do you have any additional comments or suggestions to improve, simplify or clarify the disclosure requirements within the scope of this Call for Advice, including through redrafting of instructions, and clarification of definitions, or the streamlining of terminology?

WWF position: Four points — the central one identical to WWF's Q24 proposal to ESMA. 

• Evaluate each KPI against its own job. The review should test each Article 8 KPI against its own information function (stock, facilitation, liquidity, fiduciary) rather than against the GAR; several conclusions in this paper follow from an implicit 'is it the GAR?' test that is not relevant, as no complementary indicator can pass it.
• Simplification through infrastructure, not deletion. The largest untapped burden reduction is a Commission-hosted interactive reporting and comparison online tool: guided questionnaires generated from machine-readable criteria, automatic template generation with validation, direct ESAP filing — and a public interface where every disclosure is screenable across firms and where a bank's GAR links back to the company KPIs it is computed from. Every 'relevance' problem this paper diagnoses is partly an access problem, solvable centrally, once.  
• Data quality transparency. Templates should separately identify, as tagged datapoints, the share of numerators relying on grandfathered criteria (Q12) and the share relying on estimates or proxies, so headline KPIs can be quality-adjusted by users.
• Terminology and drafting. Post-Omnibus, service labels should be harmonised between the DDA annexes and FINREP, and stable interpretations moved from Commission FAQ notices into the legal text, so the reporting rules are complete in one single instrument. 

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