Question ID:
Legal Act:
Regulation (EU) No 575/2013 (CRR)
Transparency and Pillar 3
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations:
Regulation (EU) 2022/2453 - ITS on ESG disclosures
template 10
Disclose name of institution / entity:
Name of institution / submitter:
Finance Denmark
Country of incorporation / residence:
Type of submitter:
Industry association
Subject Matter:
Template 10: Other climate change mitigating actions - Repurchases double counting

How do we avoid double counting if we invest in our own covered bonds? Both the loan and the covered bond will be in Template 10.

Background on the question:

Our members issue and invest in covered bonds making double counting an issue.

Date of submission:
Published as Final Q&A:
Final Answer:

Template 10 "Other climate change mitigating actions that are not covered in the EU Taxonomy" of Annex XXXIX to the Final draft implementing technical standards on prudential disclosures on ESG risks in accordance with Article 449a CRR covers other climate change mitigating actions and includes exposures of the institutions that are not taxonomy aligned according to Templates 7 and 8 but that still support counterparties in the transition and adaptation process for the objectives of climate change mitigation and climate change adaptation.

In this regard, only items recognised as assets and maintained on balance sheet can be considered exposures and only exposures to other counterparties should be included in the template. Therefore, when a credit institution repurchases the green bonds it has issued, as per IFRS accounting framework, they should be removed from the liabilities and then, the asset will not be recognised anymore on the balance sheet. It follows that double counting of the original asset will not occur.

Final Q&A
Answer prepared by:
Answer prepared by the EBA.