Search for Q&As

Enquirers can use various factors to search for a Q&A:

  • These include searching by the Q&A ID; legal reference, date submitted, technical standard / guideline, or by keyword if known.
  • Searches can be extended to more than one legal act, topic, technical standard or guidelines by making multiple selections (i.e. pressing 'Ctrl' on your keyboard, and selecting the relevant ones from the drop-down lists by left mouse-click).

Disclaimer:

Q&As refer to the provisions in force on the day of their publication. The EBA does not systematically review published Q&As following the amendment of legislative acts. Users of the Q&A tool should therefore check the date of publication of the Q&A and whether the provisions referred to in the answer remain the same.

Please note that the Q&As related to the supervisory benchmarking exercises have been moved to the dedicated handbook page. You can submit Q&As on this topic here.

Final Q&As Q&As under review Rejected Q&As Archived Q&As All Q&As

List of Q&A's

Scope of Template 2 restricted to NFCs?

According to the Annex II (Instructions for disclosure of ESG risks) with the regard to Template 2: Banking book – Indicators of potential climate change transition risk: Loans collateralised by immovable property – Energy efficiency of the collateral: The Template should show the gross carrying amount, as referred to in Part 1 of Annex V to Implementing Regulation (EU) 2021/451, of loans collateralised with commercial and residential immovable property and of repossessed real estate collaterals. We do not see an explicit restriction to non-financial corporates as in Template 5, for example (Definition in Template 5: … Institutions shall disclose the gross carrying amount as defined in Part 1 of Annex V to Implementing Regulation (EU) 2021/451 of those exposures towards non-financial corporates (including loans and advances, debt securities and equity instruments), classified under the accounting portfolios in the banking book in accordance with that Implementing Regulation, excluding financial assets held for trading and held for sale assets.…) The “Annotated Table Layout 330-P1-ESG 3.3.xlsx” of EBA Reporting framework 3.3 in templates D 02.00.a and D 02.00.b restricts the scope of Template 2 to non-financial corporations with the Counterparty sector field. In our opinion, the restriction is not clearly given by Regulation (EU) 2022/2453 so we ask for clarification of the fact. Is the assumption correct that in case the restriction to non-financial corporations is given in Template 2, the gross carrying amount of Template 2 column a row 0010 Total EU area and Total non-EU area 0060 is corresponding to Template 5 column b row 0100 Loans collateralised by residential immovable property, 0110 Loans collateralised by commercial immovable property and 0120 Repossessed collaterals?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2023_6896
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 27/03/2024

Validations rules for the GAR - row 290 Housing financing in template 7

Validation rules v12728_m and v12727_m are not taking into account the row 290 Housing financing. Ultimately it means this row 290 is excluded from the Total GAR assets in row 320.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2023_6901
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 27/03/2024

Template 2 - Energy efficiency of the collateral without EPC label

Could you please clarify the objective of columns o and p in rows 5 and 10 as EPC label cannot be estimated and the total is already reported in column a?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2023_6941
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 13/02/2024

Can Taxonomy eligible but not aligned exposure be included into template 10 “Other climate change mitigating actions that are not covered in the EU Taxonomy”

Question 1: Should this template include ONLY exposure NOT eligible in the EU Taxonomy? OR can exposure eligible in the EU Taxonomy but not aligned be reported as well?   Question 2: supposed the answer for question 1 is: exposure eligible in the EU Taxonomy but not aligned can reported in template 10, can we derive that such exposure will be reported in both the GAR (because eligible and not aligned) and in the template 10?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2024_6982
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 13/02/2024

Pillar 3 reporting obligations

Within the Pillar III disclosures, there are specific sectors that have a handful of dominant companies (3 or less) where the financial institutions have to disclose data for these specific NACEs separately. Would the above Eurostat-confidentiality rules stand within the Pillar III disclosures?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2023_6888
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 13/02/2024

Pillar 3 ESG Template 3 – NACE sectors scoping

The list of minimum NACE sectors provided in the template includes a combination of level 2, level 3 and level 4 NACE codes. Does this mean that if a NACE level 2 sector is mentioned, all the underlying NACE level 4 sectors are included? Or should only the level 4 NACE sectors explicitly mentioned in the list be included?  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2023_6856
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 15/01/2024

Pillar 3 ESG Template 3 – Decarbonization scenarios

Is it allowed to alternatively use reliable scenario sources other than the IEA NZE2050 scenario, which are more specific to certain sectors? Examples are the International Maritime Organization (IMO) decarbonization scenario towards 2050 for the maritime shipping sector and the CRREM 1.5C decarbonisation trajectories for commercial real estate.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2023_6855
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 12/01/2024

ESG P3 - Template 1, 5 and 7 disclosure of subsidiaries, joint venture and associates

Does Equity instruments to be reported in Pillar 3 ESG tables include also investment in subsidiaries, joint ventures and associates?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2023_6952
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 22/12/2023

Template 4 - Exposures to top 20 carbon-intensive firms

Could you please provide a single list to identify the top 20 most carbon-intensive firms?If not possible, can you define the criteria to be considered to identify the top 20 most carbon-intensive firms? For instance: sector of the counterparty, emissions scope considered (1, 2, 3)?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2023_6942
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 22/12/2023

Template 3 / Maturity of alignment targets

Template 3 requires information that is different from what banks have committed to disclose under their voluntary net zero commitments (for EU banks which are NZBA signatories): sectors are different, banks can use other benchmark net zero scenarios than the IEA NZE2050 and targets are due every 5 years under NZBA (vs. 3 years rolling at every reporting period in the ITS). Are new shorter-term targets expected to be set within the 5-year target period, or can banks report what they have indeed committed to through NZBA?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR
  • ID: 2023_6844
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 22/12/2023

Pillar 3 ESG Template 7 - Trading book

Should the Trading book be considered in the “Other assets excluded from the numerator for GAR calculation (covered in the denominator)”, as positioned under the EU Taxonomy template 1? Or should it be left in the “Other assets excluded from both the numerator and denominator for GAR calculation” category as in Pillar 3 ESG Template 7, leading to an inconsistency of reporting between the two templates?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2023_6809
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 09/10/2023

Template 10

The Annex II of the Commission Implementing Regulation (UE) 2022/2453 states that the Template 10 (“Other climate change mitigating actions that are not covered in Regulation (EU) 2020/852”) shall include “exposures of the institutions that are not taxonomy-aligned as referred to in Regulation (EU) 2020/852 according to templates 7 and 8 but that still support counterparties in the transition and adaptation process for the objectives of climate change mitigation and climate change adaptation. Those mitigating actions and activities shall include bonds and loans issued under standards other than the Union standards”. As a consequence, which of this two following options should institutions follow in order to select the Bonds and the Loans that shall be disclosed in Template 10? The Bonds and the Loans that the institution shall select to be disclose in the Template 10 are only those eligible according to the EU Taxonomy, but that are not taxonomy-aligned (i.e. Bonds and Loans that could not be covered in Template 7 or 8); The Bonds and the Loans that the institution shall select to be disclose in the Template 10 are both those eligible according to the EU Taxonomy, but that are not taxonomy-aligned and those that have been defined environmentally sustainable according to standards other than the European Union ones (i.e. Bonds and Loans that are not eligible).  

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
  • ID: 2023_6810
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 09/10/2023

Incorrect Mapping Between Pillar III Template EU CR6-A and Corep Template C 08.07

Should the Mapping Tool for Template EU CR6-A (Annex to Regulation (EU) 2021/637) be amended in a way for Template EU CR 6-A r3,2 to match with COREP Template {C 08.01, r 0080} (SPECIALIZED LENDING SLOTTING APPROACH: TOTAL) instead of COREP Template {C 08.07, r0070}?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: EBA/GL/2016/11 - Guidelines on disclosure requirements under Part Eight of CRR
  • ID: 2022_6451
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 30/01/2023

Questions on final draft implementing technical standards (ITS) on Pillar 3 disclosures on Environmental, Social and Governance (ESG) risks - template 10

Should the timelines of template 10 align with the EU Taxonomy timelines? And is it allowed to report exposures in template 10 that later will be considered EU Taxonomy aligned?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6538
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 11/11/2022

Residential Immovable Property

Paragraph of ANNEX XL - Instructions for disclosure of ESG risks states that "Institutions shall include in this template information on exposures in the banking book (including loans and advances, debt securities and equity instruments not held-for-trading and not held-for-sale), towards non-financial corporates, on loans collateralized with immovable property and on repossessed real estate collaterals, exposed to chronic and acute climate-related hazards, with a breakdown by sector of economic activity (NACE classification) and by geography of location of the activity of the counterparty or of the collateral, for those sectors and geographical areas subject to climate change acute and chronic events." It is not entirely clear to us if retail residential mortgages are in scope of template 5 for Physical Risk Discjosures? or if only loans towards NFCs shoudl be taken into account? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6514
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 11/11/2022

NACE codes for the sectors that highly contribute to climate change for Pillar 3 ESG risks disclosure, Template 1

Included in the template’s rows of the Sectors that highly contribute to climate change we find also Sector I (Accommodation and food service activities) in row 51, while in the instructions and in the Commission Delegated Regulation it’s clearly stated that such sectors include only NACE Sectors A to H and L. Is it a typo, or else what is the reason behind this? 

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6516
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 04/11/2022

Template 1: banking book (prudential disclosures on ESG risks)

Is it correct that the institutions shall only use NACE codes to classify the gross carrying amounts, and this is different from the scope in the reporting according to Article 8 of the Disclosures Delegated Act where the reference to NACE sectors is only indicative?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6490
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 20/10/2022

Template 1: banking book (prudential disclosures on ESG risks)

Is the reporting requirement of L – Real estate activities also covering residential immovable property or is it only commercial immovable property? We are uncertain since it is stated in point 7 on page 10 in Annex XL that it is exposures to non-financial corporations. However, in reporting according to the Disclosure Delegated Act residential immovable property is included.

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6492
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 20/10/2022

Template 10: other climate change mitigating actions

Should template 10 include exposures to counterparties not included in GAR e.g., exposures to be included in BTAR (template 9) or exposures that is either taxonomy eligible or aligned?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6510
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 20/10/2022

Template 5: climate change physical risk

What is meant by “other relevant sectors” - could it be a sub sector of the sectors in row 1 to 9?

  • Legal act: Regulation (EU) No 575/2013 (CRR)
  • COM Delegated or Implementing Acts/RTS/ITS/GLs: Not applicable
  • ID: 2022_6507
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as Rejected Q&A: 20/10/2022