Question ID
2024_7097
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Transparency and Pillar 3
Article
Annex XL- Instructions for reporting Template 7
Paragraph
5
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2022/2453 - ITS on ESG disclosures
Article/Paragraph
Instructions for reporting Template 7- Mitigating actions: Assets for the calculation of GAR, para.5 instructions referring to reporting of rows 290 (Housing Financing) and 300( Other local gov.)
Type of submitter
Other
Subject matter
Misalignment between scope of reportable exposures against public authorities in template 7 ( CRR) and template 1 ( EU Taxonomy - acc to 2021/2178)
Question

Should rows 280, 290 and 300 from Template 7 under ESG Disclosure only be limited to "Loans and advances" or should the scope of the rows be extended by including also debt security exposures (or other categories of exposures) in order to align with  Annex V from European Commission published on 27.6.2023 , updating Section 1.2.1.4 from 2021/2178 ?

Background on the question

We know EBA is relying on Delegated Regulation (EU) 2021/2178 and we expect the exposures reflected under Template 7 (CRR- ESG Disclosure) to be similarly defined with the similar rows reportable in Template 1 (EU Taxonomy- Annex VI), but we observe the below unclarity in requirements, leading to discrepancies.

The European Commission provided an update of 2021/2178 on 27.6.2023 through Annex V, stating the following:

"  (m) in Section 1.2.1.4., the first paragraph is replaced by the following: ‘Where credit institutions have a business model based to a great extent on financing public housing, they shall disclose a KPI concerning the proportion of exposures to public authorities financing activities .....This GAR shall be estimated and disclosed by the credit institution as a proportion of loan or debt securities exposures to municipalities financing public housing ...."

The scope was clarified through “Draft Commission Notice on the interpretation and implementation of certain legal provisions of the Disclosures Delegated Act under Article 8 of the EU Taxonomy Regulation” published on 21st of December 2023 , question 64: “loan or debt securities exposures to local governments that are covered in Section 1.2.1.4. of Annex V DDA, such exposures should be reported in the ‘of which Use of Proceeds’ column on rows corresponding to local governments in template 3.”

We would like to understand if rows 280 "Local governments financing" (including the detailed rows 290 and 300) should also be extended, compared to the current scope mentioned in the annotated tables for ESG Risk Disclosure and Pillar 3 which currently limits the exposures to Dimension: (MC:x469) Loans and advances.

Submission date
Rejected publishing date
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Status
Rejected question