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
Annex 1
Disclose name of institution / entity:
Type of submitter:
Competent authority
Subject Matter:
ITS ESG P3 - Template 2 - Column A & Totals in row 5 and 10

Two questions with regard to Template 2:  Banking book - Climate change transition risk: Loans collateralised by immovable property - Energy efficiency of the collateral:

1) Should the columns h-p sum up with b-g and simultaneously with the column a?

2)  In which lines to report a situation in which the bank estimates the energy efficiency of collateral a housing mortgage? Should rows 5 and 10 be a sum of rows 2-4 and 7-9 respectively?

Background on the question:

We received these questions from the banks, through Polish Bank Association.

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

1) Column A in Template 2 of Annex 1 to Implementing Regulation (EU) 2022/2453 should be the sum of:

- columns from H to N + O


- columns from B to G + (O * (1 - P))

Column P reports the percentage of the exposures without EPC label of the collateral for which the institution is providing EP estimates.

Columns from B to G captures Energy Performance information on loans for which there is an EPC label or it is estimated. In this latest case, the carrying amount is also reported in row 5 or 10.

In the case of exposures in non-EU countries and where there is no EPC label equivalent, institutions shall leave columns h to n blank, and disclose the information required in columns o and p and, when relevant, columns b to g with estimated data.

2) 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 estimated by institutions (in the absence of the EPC label) in rows 5 and 10. Therefore rows 5 and 10 are not a sum of rows 2-4 and 7-9 respectively.

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