Search for Q&As

Enquirers can use various factors to search for a Q&A:

  • These include searching by the Q&A ID; legal reference, date submitted, technical standard / guideline, or by keyword if known.
  • Searches can be extended to more than one legal act, topic, technical standard or guidelines by making multiple selections (i.e. pressing 'Ctrl' on your keyboard, and selecting the relevant ones from the drop-down lists by left mouse-click).

Disclaimer:

Q&As refer to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.

Please note that the Q&As related to the supervisory benchmarking exercises have been moved to the dedicated handbook page. You can submit Q&As on this topic here.

Final Q&As Q&As under review Rejected Q&As Archived Q&As All Q&As

List of Q&A's

Clarifications on the perimeter of templates 2 and 5 Collateralized loans portfolio

The Bank would like to clarify whether the same perimeter should be applied in ESG Pillar 3 Templates 2 and 5 regarding loans collateralized by residential/commercial property in column 010 (Gross Carrying Amount). Specifically, Template 2 requires banks to disclose the energy efficiency of the collateral for loans secured by immovable property, including cases where the Energy Performance Certificate (EPC) is available or unavailable, with the percentage of estimated EPCs provided when the certificate is unavailable. Based on this guidance, it seems that Template 2 would include only assets eligible for Energy Performance Certification as per relative legislation, as EPCs cannot be defined for non-eligible assets. In contrast, Template 5 would appear to cover both EPC-eligible and non-eligible assets. It would be helpful to understand if this interpretation aligns with the intended approach and whether column 010 of Template 2 should specifically reflect the subset of loans collateralized by residential/commercial property that are eligible for EPC.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2025_7292
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 28/04/2025

Denominator for GAR Green Asset Ratio (%) Calculation

Which denominator should be used in the GAR KPI templates: the corresponding Total gross carrying amount (column a) of the respective rows in template 7 "Mitigating actions: Assets for the calculation of GAR", (for example if the GAR is computed for line 0020 'Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation' in case of numerator is used the loans and advances, for example Of which environmentally sustainable Taxonomy-aligned, and in the denominator should be the similarly filtered Total gross carrying amount from the same row of template 7; The denominator should be unique, disregarding the formula level: "Total GAR assets" line 320  or  The denominator should be unique, disregarding the formula level: "Total assets in the denominator (GAR)" line 0450 ?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7272
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 28/04/2025

Clarification of reporting of lending or financing where the use of proceeds is unknown in row 440 from Template 7 (ESG Disclosure)

Should all the instruments or lending against Sovereigns, where the use of proceeds is unknown, be excluded from the numerator of Template 7 ESG Disclosure - row 460 - Sovereigns and moved to row 440 - Other assets (e.g. Goodwill, commodities etc.)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7269
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 23/05/2025

Template 3: reporting of negative values when targets are surpassed

How to report negative values in column f 'Distance to IEA NZE2050 in %*' in cases where sector targets are surpassed?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7254
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 10/04/2025

ESG P3 - Template 10 - Scope of disclosure and any relation to GAR related templates (Template 6, 7 and 8)

In Template 10, is the disclosure of the data identified at the counterparty / entity-level or data is identified at the exposure level? Can EBA help to also clarify when an exposure is reported in Template 10, would it be required for reporting in Template 6, 7 and 8 (only for the taxonomy aligned portion)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7237
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 20/03/2025

Calculation of GAR - Template 8 of ESG Templates Pillar 3

How should we correctly compute the GAR (%) stock and flow?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR
  • ID: 2024_7227
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 27/03/2025

ESG P3 - Template 1 - Reporting of column k (GHG emissions (column i): gross carrying amount percentage of the portfolio derived from company-specific reporting)

In Template 1, “column k (GHG emissions (column i): gross carrying amount percentage of the portfolio derived from company-specific reporting)”,  should the denominator used in the calculation of the percentage be: the gross carrying amount of exposures which GHG emissions are available or estimated  OR the gross carrying amount of all the exposures within the banking book portfolio regardless of whether the GHG emissions are available, estimated or not available (missing).

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7225
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 11/04/2025

GAR template 7, row 25 Households

For GAR template 7, must the row 24 “households” be always strictly equal to the sum of rows 25 +26 + 27?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7202
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 20/03/2025

Calculation of the GAR and BTAR flow versus the previous disclosure period

For Small and Non Complex Institution and other institution, should the GAR and BTAR flow be calculated on a semi-annual or an annual basis?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7126
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 07/01/2025

Template 3: Banking book - Indicators of potential climate change transition risk: Alignment metrics

Is it allowed to use another scenario than those prescribed by the IEA, as long as it is compatible with 1.5C trajectory and clearly documented in the narratives?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7102
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 28/06/2024

validation rules v16059_s and v16069_s for Template 3 are not aligned with above referenced article / paragraph in the ITS

We believe the validation rules are incorrect as they prescribe that the value should always be equal to or larger than zero, which is not always the case when applying the fixed formula for calculating the distance from the IEA Net Zero benchmark.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7100
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 05/07/2024

List of IEA Sectors in Column a vs List of IEA Sectors in the EBA3.3 Annotated Table Layout for ESG

Based on the Excel version of Template 3 (Annex XXXIX), there are 8 sectors explicitly listed in column a (Sector / IEA Sector): Power Fossil fuel combustion Automative Aviation Maritime transport Cement, clinker and lime production Iron and steel, coke, and metal ore production Chemicals And referring to the ITS Annex XL - Instructions for disclosure of ESG risks - Paragraph 19(a), it also mentions that there are 8 mandatory minimum set of sectors: 19. Institutions shall disclose in this template: a. Columns a and b: these columns include the sectors (IEA sectors in column a) under which rows 1-8 lists the mandatory minimum set of sectors, and ..... However, in the "Annotated Table Layout 330-P1-ESG 3.3.xlsx" and in the data dictionary / DPM, downloaded from EBA's website, there are only 7 values mentioned for the IEA sector -  The <Key value> (combination of all <Key value> columns when more than one) must uniquely specify each row. Value restricted to subset [CT55]: (CT:x83) Carbon intensive firms (CT:x84) 1. Power (CT:x85) 2. Fossil fuel combustion (CT:x86) 3. Automotive (CT:x87) 4. Aviation (CT:x88) 5. Maritime transport (CT:x89) 6. Cement, clinker and lime production (CT:x90) 7. Iron and steel, coke, and metal ore production   The IEA Sector named "Chemicals" is not included in the EBA 3.3 list of values. Will either the Excel version and ITS be updated to remove "Chemicals" from the list of mandatory minimum set of sectors or the "Annotated Table Layout for ESG" be updated to include "Chemicals"?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7085
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 26/07/2024

Template 8 – GAR (%)

In "Annex XL - Instructions for disclosure of ESG risk", the denominator of column "Proportion of new assets funding taxonomy relevant sectors" in Template 8 - GAR (%) "shall be the gross carrying amount of new covered assets from those assets, as defined in the instructions corresponding to column ‘a’ of Template 7". But in the document "Annex I - KPIs for credit institutions (Article 8 Taxonomy)" from EBA advises the Commission on KPIs for transparency on institutions’ environmentally sustainable activities, including a green asset ratio | European Banking Authority (europa.eu), the column "Proportion of new assets funding taxonomy relevant sectors" (sheet "4. GAR KPIs flow") has formulas with a difference of stocks in the denominator. What should be considered in the denominator? The gross carrying amount of new covered assets or the difference between gross carrying amount in current disclosure period (t) and previous disclosure period (t-1)? If it is "new covered assets", what exactly does it mean? Are these the exposures considered in current disclosure period (t), but not in previous disclosure period (t-1)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7082
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 15/11/2024

Template 5 - Reporting of gross carrying amount of exposures sensitive to chronic, acute, chronic and acute climate change events

In Template 5, should the gross carrying amount of exposures in column j (of which exposures sensitive to impact from both from chronic and acute climate change events) be reported also in column h (Of which exposures sensitive to impact from chronic climate change events) and column i (Of which exposures sensitive to impact from acute climate change events) or is the gross carrying amount of exposures reported in these 3 columns mutually exclusive?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7080
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 26/07/2024

Template 2 – Total gross carrying amount reported in column A

Should column a be equal to sum (columns b to g + o)*(1- column p) as per XBRL validation rule?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7063
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 28/06/2024

Template 5 – Total gross carrying amount reported in column B

Which gross carrying amount should be reported in column b? Should it be the total of the exposures by sector as reported in Template 1 or should it be the total of columns c to f?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7062
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 28/06/2024

Alignment of the GAR Templates 7 and 8 with the templates used by the European Commission

According to the European Commission, in the COMMISSION DELEGATED REGULATION (EU) 2023/2486 of 27 June 2023, information on the six objectives must be reported. In addition, there are differences between the EC and Pillar 3 GAR templates, such as the absence of rows for financial corporations not subject to NFRD in Pillar 3, the presence of an "Of which adaptation" in column J, which is redundant as the objective in Pillar 3 is adaptation to climate change, and the presence of columns for the use of proceeds in the EC template, whereas the columns in Pillar 3 are for specialised lending. When will the Pillar 3 ESG reporting templates (6, 7, 8 and 9) be updated in line with those of the EC?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7049
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 28/06/2024

ESG P3 - Templates 9.1 and 9.2 Decision Tree KPI BTAR for Financial Corporations

According to the question 2023_6681, the Financial Corporation located outside European Union (EU) and Financial Corporation located in EU but not subject to NFRD disclosures exposures should be reported in the row 44 of the template 7 Other assets (e.g. Goodwill, commodities etc.). In which row/group of rows should be reported in the Template 9.1 - Mitigating actions: Assets for the calculation of BTAR and Template 9.2 - BTAR Since there are only specific rows for Non-Financial Corporation?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7048
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 28/06/2024

ESG P3 - Template 5 validation rule v12726_m

Is the validation rules v12726_m correctly defined?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7041
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 09/04/2024

Val rules_v12727_m_for template 7 GAR amount is not aligned with ITS

We believe the ITS instructions 2022/2453  are incorrect for Row 32 into ITS (EU) 2022/2453. NB =  equivalent row into DPM is 0320.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_7038
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 09/04/2024