- Question ID
-
2025_7424
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Transparency and Pillar 3
- Article
-
ANNEX XL - Instructions for disclosure of ESG risks
- Paragraph
-
Template 9 - Mitigating actions: BTAR
- Subparagraph
-
44
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Draft ITS on Supervisory Reporting of Institutions
- Article/Paragraph
-
ANNEX XL - Instructions for disclosure of ESG risks
- Type of submitter
-
Consultancy firm
- Subject matter
-
BTAR voluntary disclose and DPM templates
- Question
-
Regarding the generation of DPM templates containing ESG pillar 3 disclosure, included in reporting framework 3.3 for the ad-hoc collection, according to Commission Implementing Regulation (EU) 2022/2453, template 9 – Mitigating actions: BTAR- was required for December 24 submission only on a voluntary basis.
In case a bank has decided not to publish BTAR template in the Pillar 3 disclosure for December 2024, our understanding is that there is no obligation to deliver, for December 2024, these templates (D 09.01, D 09.02.a, D 09.02.b, D 09.02.c, D 09.02.d, D 09.03.a, D 09.03.b) included in reporting framework 3.3 to keep both reports aligned (Pillar 3 disclosure, made public in February 2025, and the reporting framework 3.3 templates).
Please confirm that our view on this subject is correct.
- Background on the question
-
The decision not to disclose the Pillar 3 ESG Templates 9 (BTAR) was taken by the bank in light of the voluntary reporting of the aforementioned documents. In addition to the public disclosure, these templates are to be reported in the Reporting Framework 3.3 and should be aligned with each other.
- Submission date
- Rejected publishing date
-
- Rationale for rejection
-
This question has been rejected because the issue it deals with is already explained in paragraph 2 of Article 18a of Regulation (EU) 2021/637 and EBA Decision EBA/DC/498.
For further information on the purpose of this tool and on how to submit questions, please see “Additional background and guidance for asking questions”
- Status
-
Rejected question
