Question ID
2023_6859
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
not applicable
Type of submitter
Credit institution
Subject matter
ESG P3 - Template 3 - Indicators of potential climate change transition risk: Alignment metrics
Question

In accordance with COMMISSION IMPLEMENTING REGULATION (EU) 2022/2453 in template 3, the institution shall disclose:

1/ Alignment metric(s) (column d) applied and the closest year of reference (column e) for the alignment metric(s) for each sector. Regarding the reference date, does it refer to the reporting date? Should it therefore have to change biannually depending on the publication of ESG Pillar 3? Otherwise, how often does it have to be updated?

 2/ Institutions’ target for 3 years after the year of reference: If the reference year is different from the year of reporting (see question 1), for instance 2020 as reference date, then the target (column g) will be 2023 but as soon as the institution published the reporting for June 2024, this target won’t be relevant. Should the institution updated it and start again from 2023 as the reference date?

Background on the question

COMMISSION IMPLEMENTING REGULATION (EU) 2022/2453 request institutions to use the alignment metric(s) that can be measured against the Net Zero Emissions by 2050 Scenario (NZE2050).

Submission date
Final publishing date
Final answer

According to Annex XL of Regulation (EU) 2021/637, institutions shall disclose:

  • In column (e): “[…] the closest year of reference for the alignment metric(s) for each sector […]”, as specified in paragraph 4, point (e) under Template 3 in Annex XL. The disclosed amount shall be the nominal value related to the latest reference date for which the institution computed the chosen alignment metric, in line with how this is defined also in the EBA`s DPM under Reporting Framework 3.3. This value of the alignment metric disclosed shall be updated and recalculated on an annual basis.
  • In column (g): “[…] institutions’ target for 3 years after the year of reference indicated in column (e) and the alignment metric indicated in column (d) […]”, as specified in paragraph 4, point (g) under Template 3 in Annex XL. This implies that institutions shall update their targets with the same frequency as the values updated in columns (d) and (e), therefore on an annual basis as specified in the previous paragraph of this Q&A.
Status
Final Q&A
Answer prepared by
Answer prepared by the EBA.

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