Question ID
2024_7080
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 5
Type of submitter
Other
Subject matter
Template 5 - Reporting of gross carrying amount of exposures sensitive to chronic, acute, chronic and acute climate change events
Question

In Template 5, should the gross carrying amount of exposures in column j (of which exposures sensitive to impact from both from chronic and acute climate change events) be reported also in column h (Of which exposures sensitive to impact from chronic climate change events) and column i (Of which exposures sensitive to impact from acute climate change events) or is the gross carrying amount of exposures reported in these 3 columns mutually exclusive?

 

Background on the question

In the absence of validation rules and from the ITS' description of these 3 below-mentioned columns, it is not clear if the gross carrying amount of exposures reported in Column j will also need to be reported in column h and i of Template 5.

In the description of Column j, there is a reference "as per columns h and i" which seems to indicate that the gross carrying amount reported in this column is part of what will be reported in column h and i.

However, in the description of Column h and i, there is the usage of the word "only" i.e. chronic climate change events only, acute climate change events only.

a) Column h: of which exposures sensitive to impact from chronic climate change events
The gross carrying amount of exposures sensitive to impact from chronic climate change events only, including hazards relating to gradual changes in weather and climate and having a possible impact on economic output and productivity

b) Column i: of which exposures sensitive to impact from acute climate change events

The gross carrying amount of exposures sensitive to impact from acute climate change events only, including hazards that may cause sudden damage to properties, disruption of supply chains, depreciation of assets as well as result in operational downtime and lost manufacturing for fixed assets

c) Column j: of which exposures sensitive to impact both from chronic and acute climate change events

The gross carrying amount subject to impact from both chronic and acute climate change events, as per columns h and i

Based on the examples below, can you please help to clarify what will be reported in Template 5 - Column h, i and j - Option 1 or Option 2?

Exposure Gross Carrying Amount Sensitive to Chronic Climate Change Sensitive to Acute Climate Change
E1 1000 Yes No
E2 2000 Yes Yes
E3 3000 No No
E4 4000 No Yes

Template 5 -  Option 1 (Column j is part of column h or i)

Column h

Of which exposures sensitive to impact from chronic climate change events

Column i

Of which exposures sensitive to impact from acute climate change events

Column j

Of which exposures sensitive to impact both from chronic and acute climate change events

  
3000 (from Exposure E1+E2) 6000 (from Exposure E2+E4) 2000 (from Exposure E2)  

 

Template 5 -  Option 2 (Column h, i and j are mutually exclusive)

Column h

Of which exposures sensitive to impact from chronic climate change events

Column i

Of which exposures sensitive to impact from acute climate change events

Column j

Of which exposures sensitive to impact both from chronic and acute climate change events

  
1000 (from Exposure E1) 4000 (from Exposure E4) 2000 (from Exposure E2)  

 

 

 

 

 

 

 

Submission date
Final publishing date
Final answer

Institutions shall disclose in column j - of which exposures sensitive to impact both from chronic and acute climate change events the total gross carrying amount subject to impact from both chronic and acute climate change events in Template 5 of Annex XXXIX of Regulation (EU) 2021/637, following the instructions provided for this template in Annex XL of the same Regulation. In columns h and i, respectively, only exposures sensitive to impact from chronic climate-change events and exposures sensitive to impact from acute climate change events to be disclosed, as specified in the related instructions in Annex XL for Template 5 and presented below:

„h) of which exposures sensitive to impact from chronic climate change events

Institutions shall disclose the gross carrying amount of exposures sensitive to impact from chronic climate-change events only, including hazards relating to gradual changes in weather and climate and having a possible impact on economic output and productivity.

i) of which exposures sensitive to impact from acute climate change events

Institutions shall disclose the gross carrying amount of exposures sensitive to impact from acute climate change events only, including hazards that may cause sudden damage to properties, disruption of supply chains, and depreciation of assets.”

Therefore, columns h, i and j in this template are considered mutually exclusive and from the example approaches provided, Option 2 to be followed.

Status
Final Q&A

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