Question ID
2023_6844
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) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR
Article/Paragraph
18a and Annex II
Name of institution / submitter
French Banking Federation / Karen Degouve
Country of incorporation / residence
France
Type of submitter
Industry association
Subject matter
Template 3 / Maturity of alignment targets
Question

Template 3 requires information that is different from what banks have committed to disclose under their voluntary net zero commitments (for EU banks which are NZBA signatories): sectors are different, banks can use other benchmark net zero scenarios than the IEA NZE2050 and targets are due every 5 years under NZBA (vs. 3 years rolling at every reporting period in the ITS). Are new shorter-term targets expected to be set within the 5-year target period, or can banks report what they have indeed committed to through NZBA?

Background on the question

The differences between what seems to be requested under Template 3 and banks' voluntary commitments under NZBA are important and will be extremely difficult to comply with: for example, their is no IEA NZE2050 scenario available for all sectors mentionned in Template 3, therefore it will not be possible to measure alignment, the use of another scenario should be allowed. Additional guidance is needed on what alternative scenarios can be used.

Also, under NZBA, targets are set every 5 years and the alignment trajectory is unlikely to be linear between the baseline year and the target year, hence the difficulty to disclose in Template 3 an annual distance to target. Clarification is needed on whether this alignment metric can be identical to targets set under the NZBA commitment.

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because the issue it deals with is explained under Template 3: Banking book - Climate change transition risk: Alignment metrics in Annex XL of Regulation (EU) 2021/637. For further guidance related to Template 3 please refer to Q&As 6842, 6843 and 6859.

For further information on the purpose of this tool and on how to submit questions, please see “Additional background and guidance for asking questions”.

 

Status
Rejected question