Question ID
2024_6974
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
Template 3
Type of submitter
Credit institution
Subject matter
Template 3: Banking book - Indicators of potential climate change transition risk: Alignment metrics
Question

In relation to the minimum ‘list of NACE sectors to be considered’ in template 3, when detailed assumptions/ specific scenarios are not available on the IEA website for one of the NACE codes included in the “the minimum ‘list of NACE sectors to be considered’” (e.g. 29.32 Manufacture of other parts and accessories for motor vehicles), should it be left blank in the template?

Background on the question

The ITS instructions for template 3 state that “Institutions can find the relevant information and the applicable scenario indicators for 2030 per sector on the IEA website”. However, for certain sub-sectors included in the minimum ‘list of NACE sectors to be considered’ (e.g. 29.32 Manufacture of other parts and accessories for motor vehicles), detailed assumptions/scenarios are not available on the IEA website.

Submission date
Final publishing date
Final answer

In accordance with point (a) of paragraph 4 in the instructions of Template 3, as stipulated in Annex XL of Regulation (EU) 2021/637, institutions are required to disclose the subsectors within the sectors indicated in column (a). In Annex XXXIX of ITS on Pillar 3 disclosures, under Template 3 there is a list of NACE sectors to be considered to be included in column (b) of the template. It is not mandatory to include all of these NACE sectors listed under Template 3, nevertheless these shall be all taken into account, when determining the final subsectors to be disclosed in column (b).

Should specific scenarios or detailed assumptions for a listed NACE sub-sector not be available on the IEA website, it is acceptable for institutions to omit these sub-sectors from their reported alignment metrics in Template 3, and column (b) should include only the sub-sectors that were covered in the assumptions and related calculations. Institutions should document the rationale for any omissions, ensuring transparency in the disclosures process.

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

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