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

ESG P3 - Templates 6, 7 and 8 - Scope of application as of 31.12.2023 and institutions’ exemption from EU taxonomy reporting until mandatory CSRD reporting as of 31.12.2024

Is the institution obliged to disclose Pillar III ESG templates 6, 7 and 8 as of 31.12.2023 despite its current exemption from EU taxonomy reporting until mandatory CSRD reporting as of 31.12.2024?

  • 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_6695
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 25/08/2023

ESG P3 - Reg 2453/22 - Scope of application

What is the scope of application of Regulation (EU) 2022/2453? 

  • 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_6708
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 25/08/2023

ESG P3 - Template 7 Decision tree KPI GAR for Households

In which row/group of rows from template 7 should be disclosed Households not included in the of which populated on the template (loans collateralised by residential immovable property, building renovation loans, motor vehicle loans)?

  • 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_6780
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 25/08/2023

ESG P3 - Template 5 - Collaterals sub - totals

In Template 5, we would like to understand how to report exposures that fall into both a sector-specific row (i.e. rows 1-9) as well as a row related to real estate collateral (i.e. rows 10-11). For example, would a loan exposure to a manufacturing corporation that is collateralized by commercial real estate be reported in both row 3 and row 11, or only in row 11 (assuming that both the collateral and the location of the activity of the exposure are within the reported geography)?

  • 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: 2022_6654
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 31/03/2023

ESG P3 - Scope of application of Article 449a

Could you please clarify and confirm the scope of application of Article 449a CRR for different kinds of supervisory groups and entities, including situations where the head of the group is a (mixed) financial holding, or the group has credit institutions affiliated with the central body? In general: can a (mixed) financial holding be considered a large institution on a consolidated basis (as per the CRR definition), and therefore would it have the obligation to disclose? Or should the disclosure requirement be on the credit institution underneath? And if the latter, at what level should it disclose, at highest level of consolidation of the group, i.e. the FH or its own level? If the requirements are applicable at the top level, i.e. the (M)FH, if a financial holding is large but not listed and one of the subsidiaries underneath is listed (large or not), shall it be considered that the conditions large and listed are fulfilled?

  • 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: 2022_6652
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 10/03/2023

ESG P3 - Template 1- Attribution factor for financed emissions

In Template 1 of the final ITS, Commission Implementing Regulation (EU) 2022/2453 the GHG financed emissions should be reported in colimn i. With reference to the Annex 2 of the Regulation, institutions should  "taking into account their exposures [...] compared to total liabilities (accounting liabilities and shareholdes' equity)". This expression refers to an attributions factor that is similarly used in the GHG/PCAF-standard (EVIC, i.e. debt and equity). According to the expression, the attribution factor only applies for the "scope 3 emissions per sector" and is not explicitely named in column j for the "Of which Scope 3 financed emissions". Does the CRR-449a-attribution factor in column i and j apply for scope 1/2/3 of the counterparty? Does the attribution factor deviate from the GHG/PCAF-standard?

  • 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_6678
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 10/03/2023

ESG P3 - Template 1- Scope 3 financed emissions including scope 1 and 2 of the counterparty

In Template 1 of the final ITS (Commission Implementing Regulation (EU) 2022/2453) in column j the "Of which Scope 3 financed emissions" should be reported. Reading Annex 2 of the Regulation, "Institutions shall disclose their scope 3 emissions" where "their" refers to "institution" - this would be the scope-3-financed emissoions of the PCAF standard and therefor the total financed  emissions inclusing scope 1 /2 /3 of their (!) counterparties. Is is correct, that here only the counterparties scope-3-emissions should be reported?

  • 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_6677
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 10/03/2023

ESG P3 - Template 1- financed emissions to objects (PCAF-Standard) instead of counterparties

Regarding template 1 (ITS Commission Implementing Regulation (EU) 2022/2453) the "GHG financed emissions (scope 1, scope 2 and scope 3 emissions of the counterparty)" [see Annex 1] have to be reported. With respect to Annex 2 of the Regulation, the Reporting Standard of the Financial Industry (PCAF) is referenced (page 13), that is related to the institutions ("their") scope 3 emissions. Therefore, regarding projekt/object finance, we are not clear if the financed emissions of the specified object or the counterparty should be reported. E.g., if a bank finances/leases a car of/to a counterparty, should the scope 1/2/3 emissions of the counterparty (e.g. the company that buy the car that is partially financed by the bank)  be reported or the emissions of the car? So forth, should the attribution factor for the company or the attribution factor for the car (loan) be used?

  • 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_6676
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 10/03/2023

ESG P3 - Template 5 - NUTS codes for geographical areas outside EU

Does the regulation authorize to disclose any geographical area located outside European Union (EU) and UK?

  • 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_6679
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 10/03/2023

ESG P3 - Template 7 Decision tree KPI GAR for Financial Corporation

In which row/group of rows from template 7 should be disclosed Financial Corporation located outside European Union (EU) and Financial Corporation located in EU but not subject to NFRD disclosures?

  • 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_6681
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 10/03/2023

ITS ESG P3 - Template 4 - Top 20 emitting companies aggregation

Should reported exposures to top 20 most emitting companies be reported at a group or individual company 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: 2022_6536
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 17/02/2023

ITS ESG P3 - Non-financial risks and value chain

1. Should entities report their own non-financial risks arising from its own operations, or only the non-financial risks related to the operations of its counterparts and customers? 2. If “counterparts” includes the latter then; what is the definition of a “counterpart” ? Does it include the third party value chain e.g. suppliers and outsourcing agreements?

  • 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: 2022_6544
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 17/02/2023

ITS ESG P3 - EU Taxonomy Consolidation scope

Which consolidation scope is appropriate for the EU taxonomy disclosures in P3 ESG, given the conflicting regulatory guidance from the EU taxonomy and the NFRD and given that the EU taxonomy is disclosed in the annual report and therefore, the consolidation scope we would prefer to apply is the IFRS consolidation scope rather than the prudential scope?

  • 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: 2022_6601
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 17/02/2023

ITS ESG P3 - Template 5 - Column B carrying amount

In ESG disclosure template 5: Should the amounts disclosed in column b be equal to the carrying amounts disclosed in column a in template 1, or; Should the amounts in column b only include exposures exposed to physical risk according to the definition in the new Article 18a § 1c?

  • 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: 2022_6615
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 17/02/2023

ITS ESG P3 - Template 5 - Physical risk models - Template 1 - Power generation thresholds

Question 1: Regarding power generation thresholds as outlined in the EU article 12.1(g) of the EU Paris-aligned Benchmarks Regulation referenced in Template 1: “companies that derive 50 % or more of their revenues from electricity generation with a GHG intensity of more than 100 g CO2 e/kWh.” (a) Should we look at % revenue by separate sources of fuel or %revenue for the combined fossil fuel power generation of this company? (B) This can be interpreted as a dual factor (revenue from power generation and power generation carbon intensity). What happens if one of the factors is fulfilled, i.e. more than 50% of revenue from power generation, but not the other, i.e. less than 100 gCO2e/kWh. Question 2: Regarding Template 5, do banks need to include exposures based in non-EU geographies? There is no explicit guidance on Template 5. Question 3: Regarding Template 5, we would propose a physical risk assessment for the REMIND NDC climate change scenario (roughly 3 degree global warming in 2100) for the year 2050 (and also with data for “today” ). Is this in line with what the EBA expects? Question 4: Regarding Template 5, which option below is the correct information to fill out for column (j) “of which exposures sensitive to impact both from chronic and acute climate change events”? Question 5: Under which circumstances do banks outside the EU (e.g., Switzerland, UK or US Banks) need to report under EBA Pillar 3? Will the EBA provide a list also for these non-EU based banks falling under EBA Pillar 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: 2022_6623
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 17/02/2023

ITS ESG P3 - Template 2 - Column A & Totals in row 5 and 10

Two questions with regard to Template 2:  Banking book - Climate change transition risk: Loans collateralised by immovable property - Energy efficiency of the collateral: 1) Should the columns h-p sum up with b-g and simultaneously with the column a? 2)  In which lines to report a situation in which the bank estimates the energy efficiency of collateral a housing mortgage? Should rows 5 and 10 be a sum of rows 2-4 and 7-9 respectively?

  • 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: 2022_6625
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 17/02/2023

ITS ESG P3 - Template 1 - Scope 3 & Sector average emissions intensity

Three questions with regard to Template 1: Banking book- Climate Change transition risk: Credit quality of exposures by sector, emissions and residual maturity: 1) column I: How to understand this instruction relating to Scope 3: The estimation of scope 3 emissions per sector shall be done in a proportionate way: e.g. by taking the institution’s exposures (loans and advances, debt securities and equity holdings) towards the counterparty compared to the total liabilities (accounting liabilities and shareholders’ equity) of the counterparty? 2) column I: How will the bank use the estimates of "sector avarage emissions intensity" in template 1? 3) What type of data should the bank disclose in scope 1 and 2? In the template 1 table, there is a separate column for Scope 1, 2, and 3, and separate for Scope 3 itself. Scope 1 and 2 are the consumption of the organization, they do not concern financing – what exactly is the bank to report there?  Full Scope 1 and 2 of  clients or in some proportion?

  • 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: 2022_6626
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 17/02/2023

Maturity reporting for Pillar 3 ESG risks disclosure, Template 1 and 5

How should we treat products without stated maturity (such as on demand, equity, perpetual loans) in the maturity buckets and in the average weighted maturity computation? E.g. perpetual loans will probably end up in the >20 years bucket, but which year should we use for the computation of the average weighted maturity? Or Equity holdings are mentioned in the instructions, but it's not clear in which maturity bucket we should report them and which year to use for the computation of the average weighted maturity.  

  • 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: 2022_6515
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 25/11/2022

Template 10: other climate change mitigating actions - Columns d and e

Could you specify which kind of answers are expected under 'type of risk mitigated' (column d and e)?

  • 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: 2022_6533
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 25/11/2022

Template 5: Banking book - Climate change physical risk: Exposures subject to physical risks

What is the relation between row 1-9 and 10-12? Are rows 10-12 based on the sectors mentioned in 1-9 only, or based on all sectors (including the ones not mentioned in 1-9)?

  • 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: 2022_6541
  • Topic: Transparency and Pillar 3
  • Date of submission:
  • Published as final Q&A: 25/11/2022