- Question ID
-
2024_7100
- 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
-
Annex II - Template 3 point 4. (f)
- Type of submitter
-
Credit institution
- Subject matter
-
validation rules v16059_s and v16069_s for Template 3 are not aligned with above referenced article / paragraph in the ITS
- Question
-
We believe the validation rules are incorrect as they prescribe that the value should always be equal to or larger than zero, which is not always the case when applying the fixed formula for calculating the distance from the IEA Net Zero benchmark.
- Background on the question
-
The ITS describes that for the calculation of the distance of the alignment metric to the 2030 data points of the Net Zero Emissions by 2050 Scenario (NZE 2050) a fixed formula should be used, i.e. "metric at reference year - (IEA scenario metric in 2030)/(IEA scenario metric in 2030). The mere application of this formula can hence lead to negative values for alignment metrics with a lower value as the IEA scenario metric in 2030. The validation rules v16059_s and v16069_s are not accommodating such situations.
- Submission date
- Rejected publishing date
-
- Rationale for rejection
-
This question has been rejected because the matter it refers to has already been identified and will be considered for the forthcoming release of Report framework and related validation rules.
- Status
-
Rejected question
