Question ID
2024_6982
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Transparency and Pillar 3
Article
449a
Paragraph
N/A
Subparagraph
N/A
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2022/2453 - ITS on ESG disclosures
Article/Paragraph
Template 10
Type of submitter
Other
Subject matter
Can Taxonomy eligible but not aligned exposure be included into template 10 “Other climate change mitigating actions that are not covered in the EU Taxonomy”
Question

Question 1: Should this template include ONLY exposure NOT eligible in the EU Taxonomy? OR can exposure eligible in the EU Taxonomy but not aligned be reported as well?

 

Question 2: supposed the answer for question 1 is: exposure eligible in the EU Taxonomy but not aligned can reported in template 10, can we derive that such exposure will be reported in both the GAR (because eligible and not aligned) and in the template 10?

Background on the question

The title of this template is “Other climate change mitigating actions that are not covered in Regulation (EU) 2020/852” which make us believe that it should consider only exposure not eligible because if they are not covered in Regulation (EU) 2020/852 they cannot be classified as eligible.

ITS indicates: “This template covers other climate change mitigating actions and includes exposures of the institutions that are not taxonomy-aligned as referred to in Regulation (EU) 2020/852 according to templates 7 and 8 but that still support counterparties in the transition and adaptation process for the objectives of climate change mitigation and climate change adaptation.”

This sentence makes us believe this template can include exposure eligible in the taxonomy but not aligned.

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because it is considered that EBA guidance or clarification is not needed with regard to the issue that it raises. For example, this can be the case where it is considered that the existing regulatory framework is sufficiently clear and unambiguous, or where different practices may be possible but it is not currently necessary to harmonise these further through the Q&A process.

The Single Rule Book Q&A tool has been established to provide explanations and non-binding interpretations on questions relating to the practical application or implementation of the provisions of legislative acts referred to in Article 1(2) of the EBA’s founding Regulation, as well as associated delegated and implementing acts, and guidelines and recommendations, adopted under these legislative acts.

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Status
Rejected question