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List of Q&A's

ESG P3 - Template 1 - Reporting of column k (GHG emissions (column i): gross carrying amount percentage of the portfolio derived from company-specific reporting)

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: 25% of the portfolio has emissions derived from company-specific reporting 8% of the portfolio has emissions derived from company-specific reporting

  • 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: 2025_7426
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 10/10/2025

Clarification of reporting of lending or financing where the use of proceeds is unknown in row 440 from Template 7 (ESG Disclosure)

Should all the instruments or lending against Sovereigns, where the use of proceeds is unknown, be excluded from the numerator of Template 7 ESG Disclosure - row 460 - Sovereigns and moved to row 440 - Other assets (e.g. Goodwill, commodities etc.)?

  • 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_7269
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 23/05/2025

ESG P3 - Template 1 - Reporting of column k (GHG emissions (column i): gross carrying amount percentage of the portfolio derived from company-specific reporting)

In Template 1, “column k (GHG emissions (column i): gross carrying amount percentage of the portfolio derived from company-specific reporting)”,  should the denominator used in the calculation of the percentage be: the gross carrying amount of exposures which GHG emissions are available or estimated  OR the gross carrying amount of all the exposures within the banking book portfolio regardless of whether the GHG emissions are available, estimated or not available (missing).

  • 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_7225
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 11/04/2025

Template 8 – GAR (%)

In "Annex XL - Instructions for disclosure of ESG risk", the denominator of column "Proportion of new assets funding taxonomy relevant sectors" in Template 8 - GAR (%) "shall be the gross carrying amount of new covered assets from those assets, as defined in the instructions corresponding to column ‘a’ of Template 7". But in the document "Annex I - KPIs for credit institutions (Article 8 Taxonomy)" from EBA advises the Commission on KPIs for transparency on institutions’ environmentally sustainable activities, including a green asset ratio | European Banking Authority (europa.eu), the column "Proportion of new assets funding taxonomy relevant sectors" (sheet "4. GAR KPIs flow") has formulas with a difference of stocks in the denominator. What should be considered in the denominator? The gross carrying amount of new covered assets or the difference between gross carrying amount in current disclosure period (t) and previous disclosure period (t-1)? If it is "new covered assets", what exactly does it mean? Are these the exposures considered in current disclosure period (t), but not in previous disclosure period (t-1)?

  • 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_7082
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 15/11/2024

Disclosures in case of lack of label in EPCs

What shall be reported in columns h-n in case local EPCs do not present labels in the form of letters (A-G), but only level of energy efficiency? Shall these columns be left blank or “0” can be disclosed? Is it acceptable that the banks remove these columns from the template and do not disclose them at all? In addition, what shall be reported in this case in columns o and p? Column “o” is named as “Without EPC label of collateral” and it may indicate that the values to be disclosed in this column refer to the information in columns h-n.  

  • 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_7013
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 20/09/2024

List of IEA Sectors in Column a vs List of IEA Sectors in the EBA3.3 Annotated Table Layout for ESG

Based on the Excel version of Template 3 (Annex XXXIX), there are 8 sectors explicitly listed in column a (Sector / IEA Sector): Power Fossil fuel combustion Automative Aviation Maritime transport Cement, clinker and lime production Iron and steel, coke, and metal ore production Chemicals And referring to the ITS Annex XL - Instructions for disclosure of ESG risks - Paragraph 19(a), it also mentions that there are 8 mandatory minimum set of sectors: 19. Institutions shall disclose in this template: a. Columns a and b: these columns include the sectors (IEA sectors in column a) under which rows 1-8 lists the mandatory minimum set of sectors, and ..... However, in the "Annotated Table Layout 330-P1-ESG 3.3.xlsx" and in the data dictionary / DPM, downloaded from EBA's website, there are only 7 values mentioned for the IEA sector -  The <Key value> (combination of all <Key value> columns when more than one) must uniquely specify each row. Value restricted to subset [CT55]: (CT:x83) Carbon intensive firms (CT:x84) 1. Power (CT:x85) 2. Fossil fuel combustion (CT:x86) 3. Automotive (CT:x87) 4. Aviation (CT:x88) 5. Maritime transport (CT:x89) 6. Cement, clinker and lime production (CT:x90) 7. Iron and steel, coke, and metal ore production   The IEA Sector named "Chemicals" is not included in the EBA 3.3 list of values. Will either the Excel version and ITS be updated to remove "Chemicals" from the list of mandatory minimum set of sectors or the "Annotated Table Layout for ESG" be updated to include "Chemicals"?  

  • 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_7085
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 26/07/2024

Template 5 - Reporting of gross carrying amount of exposures sensitive to chronic, acute, chronic and acute climate change events

In Template 5, should the gross carrying amount of exposures in column j (of which exposures sensitive to impact from both from chronic and acute climate change events) be reported also in column h (Of which exposures sensitive to impact from chronic climate change events) and column i (Of which exposures sensitive to impact from acute climate change events) or is the gross carrying amount of exposures reported in these 3 columns mutually exclusive?  

  • 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_7080
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 26/07/2024

Template 9.1 – Mitigating actions: Assets for the calculation of BTAR

Should institutions check the compliance of ‘do no significant harm’ and ‘minimum safeguards’ requirements for BTAR exposures?

  • 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_7004
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 26/07/2024

Reference of the cells and reports layouts to use for the public disclosures (NOT the XBRL reporting)

Question 1: What are the cells references that must be publicly disclosed into annual and semiannual public disclosures: the reference of the cells from the ITS or the references of the cells from the XBRL? Question 2: What are the reports layouts that must be publicly disclosed into annual and semiannual public disclosures: the layout from the ITS or the layout from the XBRL?

  • 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_6915
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 26/04/2024

Template 1 - exposures towards companies excluded from EU Paris-aligned Benchmarks

Should the EU Paris-aligned Benchmarks exclusion criteria be applied at consolidated group level and to that end, exclude the total gross carrying amount of the exposure towards the consolidated group level?

  • 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_6940
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 26/04/2024

Template 3: Banking book - Indicators of potential climate change transition risk: Alignment metrics

In relation to the minimum ‘list of NACE sectors to be considered’ in template 3, when detailed assumptions/ specific scenarios are not available on the IEA website for one of the NACE codes included in the “the minimum ‘list of NACE sectors to be considered’” (e.g. 29.32 Manufacture of other parts and accessories for motor vehicles), should it be left blank in the template?

  • 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_6974
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 26/04/2024

Template 2 - EBA val rules and Column 0160 Of which level of energy efficiency EP score in kWh_m of collateral estimate

Question 1: Are the validation rules v16092_m; v16090_m; v16088_m; v16086_m; v16084_m;v16082_m; v16080_m; v16078_m; v16049_m correctly defined?    Question 2:  How to deal with exposure for which and EPC is available, but the Level of energy efficiency (EP score in kWh/m² of collateral) is absent from the EPC?

  • 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_6983
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 26/04/2024

Template 3: Banking book - Indicators of potential climate change transition risk: Alignment metrics

1.           Should the year of reference column refer to the year for which the latest emission intensities are available for a specific sector included in the template? 2.           Could you please confirm if alignment metrics should be calculated based on actual gross carrying amount (column c) in combination with the latest emission intensity information that is available for the specific sector?

  • 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_6975
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 22/03/2024

Sum of breakdowns in Template 1 (financed emissions)

Should the sum of NACE sub-sectors for GHG financed emissions in columns i and j of Template 1 be equal to the total GHG financed emissions for that NACE sector?

  • 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_6973
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 22/03/2024

Template 1 – Equity instruments

The instructions state “Institutions shall disclose the gross carrying amount, referred to 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 in the accounting portfolios in the banking book in accordance with that Implementing Regulation, excluding financial assets held for trading or held for sale assets”.In this case, should the definition of equity instruments also include investments in subsidiaries, joint ventures and associates, or should entities consider the definition of accounting portfolios of financial instruments provided by Annex V of FINREP, which specifically excludes investments 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_6954
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 22/03/2024

ITS ESG P3 - Template 2 - Should loan/collateral ratio (loan-to-value) be taken into account?

We have interpreted column a in Template 2 to be filled in with the gross carrying amount of the loan collateralized with commercial and residential immovable property and of repossessed real estate collaterals. What if the collateral value is less than the gross carrying amount of the loan? Should we in this case fill in the gross carrying amount of the loan or use the amount of the loan that is actually collateralized with commercial/residential immovable property in Template 2? 

  • 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_6897
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 22/03/2024

ESG P3 - Template 3 - Indicators of potential climate change transition risk: Alignment metrics

In accordance with COMMISSION IMPLEMENTING REGULATION (EU) 2022/2453 in template 3, the institution shall disclose: 1/ Alignment metric(s) (column d) applied and the closest year of reference (column e) for the alignment metric(s) for each sector. Regarding the reference date, does it refer to the reporting date? Should it therefore have to change biannually depending on the publication of ESG Pillar 3? Otherwise, how often does it have to be updated?  2/ Institutions’ target for 3 years after the year of reference: If the reference year is different from the year of reporting (see question 1), for instance 2020 as reference date, then the target (column g) will be 2023 but as soon as the institution published the reporting for June 2024, this target won’t be relevant. Should the institution updated it and start again from 2023 as the reference date?

  • 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_6859
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 15/12/2023

Template 3 / Exposures to companies operating in several sectors

In Template 3, should corporate exposures corresponding to general-purpose financing lines be split across different sectors according to “the counterparties’ activity distribution, including by counterparties’ turnover by activity” (and therefore several different NACE codes), or should corporate exposures be fully allocated to one NACE code only corresponding to its main activity (as in template 1)? In the first option, how granular is the activity distribution expected to be reported, is there a minimum threshold of turnover to start reporting an activity? How is the information expected to be collected if not communicated by the corporates, can external data providers be used?

  • 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_6842
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 15/12/2023

Template 3 / Level of NACE codes to use

In Template 3, different levels of NACE code are indicated (level 1, 2, 3 or 4). What does this mean in practice, should banks report their full exposures falling under each level, or should exposures be reported in one category only? For example, for the fossil fuel sector a level-one NACE code is indicated (NACE code “6”) along with level 2 and 3 NACE codes (NACE code 61, 610…) – should exposures reported under code 610 also be included in exposures reported under 61 and 6? Please note that some NACE codes are overlapping (e.g. NACE code 8 is proposed for fossil fuel combustion and NACE code 89 is proposed for cement) – should exposures reported under 89 also be included in exposures reported under 8?

  • 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_6843
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 15/12/2023

ESG P3 - Template 2 and 5 - Gross carrying amount for loans collateralized by RRE/CRE and multiple collaterals

Question 1: For loans collateralised by CRE and/or RRE, to be reported in template 2 & 5, does the regulation allow to have their gross carrying amount not matching the gross carrying amount of the same loans reported in FINREP? Question 2: Does Q&A 6517 apply for both template 2 and 5 or only for template 5?

  • 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_6714
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 13/10/2023