Question ID
2023_6917
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
D 05.00.b - Banking book - Indicators of potential climate change physical risk: Exposures subject to physical risk (II)
Type of submitter
Other
Subject matter
What to report in D 05.00.b - Banking book - Indicators of potential climate change physical risk?
Question

Question 1: what are the data/NACE code in scope to be reported for template D 05.00.b - Banking book - Indicators of potential climate change physical risk?

Question 2: what is the level of NACE code to disclose in template D 05.00.b - Banking book - Indicators of potential climate change physical risk?

Background on the question

CRR ITS 2022_2453 provides a pdf and an Excel with the list of templates to disclose:

 

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

 

With the introduction of ESG DPM 3.3, EBA is making a breakdown with:

 

 

  1. D05.00a: with a fix list of rows based on the Section level of NACE code.
  2. D05.00b: with dynamic rows based on (detailed?) NACE code.

 

For us it is not very clear if EBA expects for this report D05.00b:

 

 

 

  1. Any NACE codes, irrespective if reported or not in report D05.00a

     

  2. Only the NACE code which are not reported in report D05.00a (= for instance NACE code starting with I (accommodation …), K (financial …))

     

  3. Only the NACE which are reported in report D05.00a

     

  4. Something else ….

     

 

 

 

FYI:

 

 

  1. The note in yellow in the DPM excel “Annotated Table Layout 330-P1-ESG 3.3.xlsx “ sheet “D 05.00.b“ cell D/11 () shows NACE codes which are reported in report D05.00a, but not the entire list …
  2. The column 0005 name is “Other relevant sectors (breakdown below where relevant)” which makes us believe not included in D05.00a …

 

 

NACE code are structured in 4 levels (https://ec.europa.eu/eurostat/statistics-explained/index.php?title=NACE_background#Structure_and_coding_of_NACE). It is not clear if EBA gives flexibility to the disclosing entity to choose at their discretion the NACE code level to disclose. Or, if EBA only and always expect a specific level. In this later case EBA should specify the NACE code level expected.

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because the issue it deals with is already explained and addressed in Regulation (EU) 2021/637. 

The instructions provided in Annex XL of Regulation (EU) 2021/637 for Template 5, paragraph 26 state ['...Institutions shall disclose information by NACE codes with the level of granularity required in the rows of the template.']. The NACE codes to be considered are also defined in Template 5 in Annex XXXIX of the same Regulation, rows 1 to 9 and with row 13 for any further relevant sectors (discretion of the reporting institution). The related EBA DPM 3.3 is aligned with these requirements.

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Status
Rejected question