Question ID
2025_7426
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Transparency and Pillar 3
Article
449a
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2022/2453 - ITS on ESG disclosures
Article/Paragraph
Template 1
Type of submitter
Consultancy firm
Subject matter
ESG P3 - Template 1 - Reporting of column k (GHG emissions (column i): gross carrying amount percentage of the portfolio derived from company-specific reporting)
Question

In Template 1, “column k (GHG emissions (column i): gross carrying amount percentage of the portfolio derived from company-specific reporting)”,  could you please clarify how the percentage should be calculated in the total column (56)? In the interest of precision and clarity, it is essential to determine whether the total percentage should be calculated over the total gross carrying amount of the template or only take into account the exposures that contribute significantly to climate change and replicate the same percentage that appears in row 1. This determination is crucial as only emissions from sectors that contribute substantially to climate change should be reported.

Example:

Exposure Gross Carrying Amount Gross Carrying Amount of the portfolio with derived from company-specific reporting
Highly contributing sectors exposure 100 25
Non-highly contributing sectors exposure 200 Not disclosed
Total exposure 300 25

The denominator of the row 56 i.e. gross carrying amount used in the calculation of the percentage for column k will be based on 100 or 300?

Final result should be:

  1. 25% of the portfolio has emissions derived from company-specific reporting
  2. 8% of the portfolio has emissions derived from company-specific reporting
Background on the question

According to the ITS, Template 1 reports exposures towards non-financial corporates, including loans and advances, debt securities and equity instruments, classified in the accounting portfolios in the banking book excluding financial assts held for trading or held for sale assets. 

The instructions given for the “column k (GHG emissions (column i): gross carrying amount percentage of the portfolio derived from company-specific reporting)” of Template 1 is that:

“Institutions shall indicate the percentage of the portfolio (gross carrying amount of the exposures) for which they have been able to estimate their counterparties’ scope 1, 2 and 3 emissions associated with institutions’ lending and investment activities based on information disclosed by their counterparties or reported to the institution on bilateral basis”.

It should be noted that emissions for exposures towards sectors other than those that highly contribute to climate change are not required to be disclosed. This results in a mismatch between the numerator (gross carrying amount of the exposures with emissions derived from company-specific reporting from sectors that highly contribute to climate change) and the denominator (gross carrying amount of non-financial corporations, including sectors that highly contribute and others).

Submission date
Final publishing date
Final answer

The percentage disclosed in row 56 of column k of Template 1 of Annex XXXIX of Regulation (EU) 2021/637 should be calculated taking the exposures that highly contribute to climate change, therefore the same percentage should be disclosed as in row 1.

For the next amendment of the Commission Implementing Regulation (EU) 2024/3172, this cell in row 56 will be proposed to be greyed out.

Without prejudice how to disclose this cell subject of this Q&A, please also refer to Q&A 2024_7225 for clarification regarding the reporting of the cells in column k for rows 1 - 52 of Template 1.

Status
Final Q&A
Answer prepared by
Answer prepared by the EBA.

Disclaimer

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