Template 2 of Annex XXXIX to the Final draft implementing technical standards on prudential disclosures on ESG risks in accordance with 449a CRR – Is row 5 a sub-set of rows 2/3/4?

From the wording of the ITS it looks like the total Gross carrying amount should be split iinto row 2/3/4 (RRE/CRE/REPOSSED).

As explained in the Annex XL - Instructions for disclosure of ESG risks to the Final draft implementing technical standards on prudential disclosures on ESG risks in accordance with Article 449a CRR, Template 2 will show the gross carrying amount of loans collateralised with commercial and residential immovable property and of repossessed real estate collaterals, including information on the level of energy efficiency of the collaterals measured in terms of kWh/m² energy consumption.

In 'columns b' to 'g' institutions shall disclose the gross carrying amount of exposures by energy efficiency buckets based on the specific energy consumption of the collateral in kWh/m², as indicated in the EPC label of the collateral or estimated by institutions in the absence of the EPC label. In rows 5 and 10 of the template it should be indicated the extent to which this data is estimated and not based on EPC labels.

Row 5 is a subset of rows 2/3/4, as it should include the portion of the gross carrying amount of loans whose collaterals’ level of efficiency is estimated (without EPC label).