- Question ID
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2024_6983
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Transparency and Pillar 3
- Article
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449a
- Paragraph
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N/A
- Subparagraph
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N/A
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Regulation (EU) 2022/2453 - ITS on ESG disclosures
- Article/Paragraph
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Template 2
- Type of submitter
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Other
- Subject matter
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Template 2 - EBA val rules and Column 0160 Of which level of energy efficiency EP score in kWh_m of collateral estimate
- Question
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Question 1: Are the validation rules v16092_m; v16090_m; v16088_m; v16086_m; v16084_m;v16082_m; v16080_m; v16078_m; v16049_m correctly defined?
Question 2: How to deal with exposure for which and EPC is available, but the Level of energy efficiency (EP score in kWh/m² of collateral) is absent from the EPC?
- Background on the question
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Question 1:
By strictly applying the EBA validation rules, it is impossible to be successful unless having 0% for “Of which level of energy efficiency (EP score in kWh/m² of collateral) estimated”.
Note also the answer of EBA Q&A_ 2022_6625 is not aligned with the EBA validation rules, an example to highlight:
EBA validation rules v16084_m for row 020: {D 02.00.a, c0010} = ({D 02.00.a, c0020} + {D 02.00.a, c0030} + {D 02.00.a, c0040} + {D 02.00.a, c0050} + {D 02.00.a, c0060} + {D 02.00.a, c0070} + {D 02.00.a, c0150}) * (1 - {D 02.00.b, c0160}). Here the entire sum of columns 20+30+40+50+60+70+150 must be multiplied by (1 - {D 02.00.b, c0160})
EBA Q&A_ 2022_6625: Column A in Template 2 of Annex 1 to Implementing Regulation (EU) 2022/2453 should be the sum of columns from B to G + (O * (1 - P)). Here only the Column 150/row20 must be multiplied by (1 - {D 02.00.b, c0160})
Question 2:
Until 31/12/2020, the EPC regulation NEN 7120 in The Netherlands was providing an energy performance label but was not providing any kWh/m2 energy consumption.
Since the 01/01/2021, the new EPC regulation NTA 8800 in place in the Netherlands is providing an energy performance label AND the kWh/m2 energy consumption.
It means we can have a real situation where an EPC is available but without any information on kWh/m2 energy consumption. This situation can have an impact on the supposed correct validation rules proposed in EBA Q&A_ 2022_6625:
- See example 4 in the attached file: if we consider that the kWh/m2 energy consumption is internally estimated by the bank, we failed with validation rules proposed in EBA Q&A_ 2022_6625
- See example 5 in the attached file: if we consider that the kWh/m2 energy consumption is NOT internally estimated by the bank (= is coming from the EPC), we success with validation rules proposed in EBA Q&A_ 2022_6625
- Submission date
- Final publishing date
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- Final answer
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Response to Question 1
All these validation rules have been reviewed and deactivated under the new validation rules release (as of 22 March 2024), uploaded to the Reporting framework 3.4.
Response to Question 2
When the EPC label is available for the collateral of the exposure in scope for Template 2 of Annex XXXIX of Regulation (EU) 2021/637, but the exact EP score in kWh/m2 is absent, these cases should be disclosed in rows 5 or 10 “Of which Level of energy efficiency (EP score in kWh/m² of collateral) estimated” under columns b-g based on the estimated EP score and also depending on whether it should be disclosed under EU area or non-EU area. Under columns h-n, these cases should be allocated to the respective column based on the available EPC label and to disclose them in rows 2-4 or 7-9 following the specification of these rows and also depending on whether it should be disclosed under EU area or non-EU area.
- Status
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Final Q&A
- Answer prepared by
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Answer prepared by the EBA.
Disclaimer
The Q&A refers to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.