- Question ID
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2023_6915
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Transparency and Pillar 3
- Article
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449a
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Regulation (EU) 2022/2453 - ITS on ESG disclosures
- Article/Paragraph
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no paragraph
- Type of submitter
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Other
- Subject matter
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Reference of the cells and reports layouts to use for the public disclosures (NOT the XBRL reporting)
- Question
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Question 1: What are the cells references that must be publicly disclosed into annual and semiannual public disclosures: the reference of the cells from the ITS or the references of the cells from the XBRL?
Question 2: What are the reports layouts that must be publicly disclosed into annual and semiannual public disclosures: the layout from the ITS or the layout from the XBRL?
- Background on the question
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CRR ITS 2022_2453 provides a pdf and an Excel with the list of templates to disclose:
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R2453
ESG 3.3 DPM 3.3.0 provides the Excel templates in relation with the taxonomy available into the zip file https://www.eba.europa.eu/sites/default/documents/files/document_library/Risk%20Analysis%20and%20Data/Reporting%20Frameworks/Reporting%20Framework%203.3/1060920/DPM%20tabe%20layout%20and%20data%20point%20categorizaiton%207.zip
The references of the cells (rows and columns) are different between the ITS and the XBRL, but ultimately it is the same data to report in both the ITS and the XBRL.
For instance, for template 1 Banking book- Indicators of potential climate Change transition risk: Credit quality of exposures by sector, emissions and residual maturity:
- ITS references of the columns: a, b, c, d, e, etc. While for the XBRL the references of the columns are 0010, 0020, 0030, 0040, 0050, etc.
- The same for rows: ITS references of the rows: 1, 2, 3, 4, 5, etc. While for the XBRL the references of the rows are 0010, 0020, 0030, 0040, 0050, etc.
For ultimate end user of the public disclosure, these differences have no impact because they know only the public disclosure and they are not aware about the XBRL references.
For banks, regulators and software providers it has impacts because they are working on the 2 set of reports (ITS and XBRL) but it does not generate big challenges except the fact to have 2 vocabularies of cells reference which is not always user friendly.
The breakdown of each report is different between the ITS and the XBRL, for instance for Template 2: Banking book - Indicators of potential climate change transition risk: Loans collateralised by immovable property - Energy efficiency of the collateral: In the ITS there is a single report while in the XBRL the report is split in 2:
- D 02.00.a: with 10 rows and 15 columns
- D 02.00.b: with 1 row and 1 column which is column 0160 “Of which level of energy efficiency (EP score in kWh/m² of collateral) estimated”
For ultimate end user of the public disclosure, the ITS layout is easy to read, to understand and to analyze while the “technical” XBRL layout is less user friendly.
But technically speaking, it could mean banks will have to develop, support, maintain two distinct set of reports: one for the public disclosure (= the ITS) and one for the XBRL reporting. It will increase the costs and can generate inconsistencies, reconciliation issues, etc.
- Submission date
- Final publishing date
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- Final answer
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The format and structure of the publicly disclosed Pillar 3 templates of Regulation (EU) 2021/637 (Pillar 3 ITS) should be based on the related Annexes of that Regulation. The table layouts, naming and numbering of the rows and columns of the templates should be the same as they are defined in the specific Annexes of this Regulation.
- Status
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Final Q&A
- Answer prepared by
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Answer prepared by the EBA.