Question ID
2024_7085
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Transparency and Pillar 3
Article
449a
Paragraph
ANNEX XXXIX - Template 3
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2022/2453 - ITS on ESG disclosures
Article/Paragraph
19a
Type of submitter
Other
Subject matter
List of IEA Sectors in Column a vs List of IEA Sectors in the EBA3.3 Annotated Table Layout for ESG
Question

Based on the Excel version of Template 3 (Annex XXXIX), there are 8 sectors explicitly listed in column a (Sector / IEA Sector):

  1. Power
  2. Fossil fuel combustion
  3. Automative
  4. Aviation
  5. Maritime transport
  6. Cement, clinker and lime production
  7. Iron and steel, coke, and metal ore production
  8. Chemicals

And referring to the ITS Annex XL - Instructions for disclosure of ESG risks - Paragraph 19(a), it also mentions that there are 8 mandatory minimum set of sectors:

19. Institutions shall disclose in this template:

a. Columns a and b: these columns include the sectors (IEA sectors in column a) under which rows 1-8 lists the mandatory minimum set of sectors, and .....

However, in the "Annotated Table Layout 330-P1-ESG 3.3.xlsx" and in the data dictionary / DPM, downloaded from EBA's website, there are only 7 values mentioned for the IEA sector - 

The <Key value> (combination of all <Key value> columns when more than one) must uniquely specify each row. 
Value restricted to subset [CT55]: 
(CT:x83) Carbon intensive firms 
(CT:x84) 1. Power 
(CT:x85) 2. Fossil fuel combustion 
(CT:x86) 3. Automotive 
(CT:x87) 4. Aviation 
(CT:x88) 5. Maritime transport 
(CT:x89) 6. Cement, clinker and lime production 
(CT:x90) 7. Iron and steel, coke, and metal ore production 
 

The IEA Sector named "Chemicals" is not included in the EBA 3.3 list of values.

Will either the Excel version and ITS be updated to remove "Chemicals" from the list of mandatory minimum set of sectors or the "Annotated Table Layout for ESG" be updated to include "Chemicals"?

 

Background on the question

In Template 3 of Annex XXXIX - Prudential disclosures on ESG risks (Article 449a CRR), Banks are asked to disclose their alignment efforts with the Paris Agreement objectives for a selected number of sectors.

The list of IEA sectors in the Excel version of this template contains 8 mandatory minimum set of sectors but there are only 7 list of values in the EBA ESG3.3 DPM / "Annotated Table Layout".

Submission date
Final publishing date
Final answer

Based on Template 3 in Annex XXXIX of Regulation (EU) 2021/637 and following its related instructions in Annex XL of the same Regulation institutions shall present also IEA sector Chemicals as one of the rows for Template 3. The related DPM will be amended accordingly with the next reporting framework release.

Status
Final Q&A

Disclaimer

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