According to the ITS, Template 10 is to report other climate change mitigating actions and includes exposures of the institutions that are not taxonomy aligned according to templates 7 and 8 but that still support counterparties in the transition and adaption process for the objectives of climate change mitigation and climate change adaptation. These mitigation actions and activities shall include bonds and loans issued under standards other than the EU standards.

Question (a) Is the data to be reported in this template identified at the exposure level because the type of instruments reported in this template such as green bonds; sustainable bonds that are linked to aspects on climate change, etc.  are exposures with known use of proceeds (taxonomy alignment assessed based on the project or activities to which the proceeds will be applied)? Or the data to be reported in this template is identified at the counterparty / entity-level as the taxonomy alignment based on economic activities is assessed at counterparty / entity level?

Question (b) Can EBA help to clarify whether an exposure which has been identified to be reported in Template 10, can a  portion of the same exposure (the taxonomy aligned portion) be reported in Template 6, 7 and 8? Or when an exposure is reported in Template 10, it is no longer considered under GAR, so, it will not be reported in Template 6, 7 and 8?

For example, a counterparty (C1) is 40% taxonomy aligned and has two loans: A1 and A2.

Disclosure #1: Loan A1 is a green loan issued under standards other than EU and the aligned portion is reported in Template 7 and 8 but the non-aligned portion is reported in Template 10

Disclosure #2: Loan A1 is a green loan issued under standards other than EU and the entire gross carrying amount is excluded from GAR i.e. only to be reported in Template 10 and not in Template 6, 7 and 8.

The other loan A2 belonging to the same counterparty will be reported in Template 6, 7 and 8.