Question ID
2023_6780
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Transparency and Pillar 3
Article
449a
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2022/2453 - ITS on ESG disclosures
Article/Paragraph
n.a.
Type of submitter
Credit institution
Subject matter
ESG P3 - Template 7 Decision tree KPI GAR for Households
Question

In which row/group of rows from template 7 should be disclosed Households not included in the of which populated on the template (loans collateralised by residential immovable property, building renovation loans, motor vehicle loans)?

Background on the question

Both commission implementing regulation (EU) 2022/2453 and Delegated Regulation (EU) 2021/2178 don’t provide enough detailed instructions to clearly derive, without room for interpretation, where to disclose all “categories” of Households.

On EBA Report "Advice to the commission on Article 8 Taxonomy regulation" page 38 mentions the formula to be implemented where only transitional activities are taken into consideration in the denominator.

Similar to Q&A 6681 referred to Financial Corporations, if you could clarify it will be helpful and it will enable to disclose an accurate GAR and it will avoid different interpretations between institutions.

 

Submission date
Final publishing date
Final answer

According to Annex V., 1.2.1.3 of the Regulation (EU) 2021/2178, the Green asset ratio for retail exposures shall apply only to investments relevant for climate change mitigation.

Template 7 - Mitigating actions: Assets for the calculation of GAR of the Regulation (EU) 2022/453 (ITS on ESG disclosures) do not foresee a specific line to report Households exposures other than the ones included in the template (loans collateralised by residential immovable property, building renovation loans, motor vehicle loans).

As a consequence, institutions should report such exposures in Template 7 either in row 24 in case they are considered covered assets in both numerator and denominator of the GAR, or in row 44 “Other assets” in case they are excluded from the numerator but covered in the denominator of the GAR.

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

Disclaimer

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