Regulatory reporting for ESG is addressed in the following regulations:

Regulation (EU) 2022/2453 – Annex XII, Template 1, point 4 (i)
Regulation (EU) 2020/1818 – Recital (6)
 

There is an inconsistency between the regulations above and the EBA validations of the ESG reporting (tempalte 1) in respect of accommodation and food service activities.

In the explanation of Template 1, point 4 (i) of Regulation (EU) 2022/2453, it is stated:
“Financed GHG emissions (Scope 1, 2 and 3 emissions of the counterparty) (in tonnes of CO₂ equivalent). Where available, institutions shall disclose estimates of the scope of their counterparties’ Scope 3 GHG emissions in tonnes of CO₂ (tCO₂) as part of column (i). The disclosure covers all sectors and sub-sectors that contribute significantly to climate change, including the oil, gas, mining and transport sectors (as per recital 6 of Delegated Regulation (EU) 2020/1818) which are listed in rows 2 to 52 of the template."

Therefore, accommodation and food activities sector is considered a significant contributor to climate change both in the regulation and in template 1 (row 51).

However, in Recital 6 of Delegated Regulation (EU) 2020/1818, accommodation and food activities sector is excluded from significant contributors to climate change: “The sectors listed in Sections A to H and Section L of Annex I to Regulation (EC) No 1893/2006 of the European Parliament and of the Council (5), including the oil, gas, mining and transport sectors, contribute significantly to climate change.”

When populating Template 1, the reporting on accommodation and food service activities as significant contributor to climate change results in the breach of an EBA validation that prevents the reporting from going through.

Therefore, we seek clarification from  EBA as to how this sector should be considered for the purpose of the reporting.