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
Disclose name of institution / entity:
Type of submitter:
Credit institution
Subject Matter:
ESG P3 - Template 7 Decision tree KPI GAR for Households

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.


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

According to Annex V., 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.

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