EBA · 2023_6677 Final Q&A

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

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
449a
Topic
Transparency and Pillar 3
Submitted by
Credit institution
Submitted
2023-01-03
Answered
2023-03-10
Answer provided by
ESAs (EBA, ESMA, EIOPA)
Browse ECB SSM Register → More Q&As on this regulation →

Question

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?

Background

While getting more and more involved in GHG Accounting, we have the feeling that the definition and reflexive use of "their" is not always clear in the Annex. Keep in mind, that financed scope 1/2/3-emissions of the counterparties are altogether scope-3-emissions of the institution. Therefore, we ask to have this clear here.

Answer

According to the instructions for Template 1, included in the Annex II of the Commission Implementing Regulation (EU) 2022/2453, in column “I” institutions shall disclose their scope 3 GHG financed emissions, which are scope 1, 2 and 3 emissions of their counterparties. Regarding column “j” (“Of which Scope 3 financed emissions”), the first sentence of the instructions for this particular column states that : Institutions shall disclose their counterparties’ scope 3 emissions associated with institutions’ lending and investment activities.  It means that column “j” is dedicated specifically for scope 3 emissions of the counterparties.

Original source: European Banking Authority, Q&A ID 2023_6677

This Q&A is published by European Banking Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

Similar Q&As

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

Answered 2023-03-10

ESG P3 - Template 1- Attribution factor for financed emissions

Answered 2023-03-10

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

Answered 2023-02-17

ITS ESG P3 - Annex II, Templates 1, 2, 4, 5

Answered 2023-02-17

Sum of breakdowns in Template 1 (financed emissions)

Answered 2024-03-22

More Q&As on this topic

Pillar 3 Data Hub CONDIS: ITS and reporting framework modelling constraint affecting EU LI1/LI2/CC2

Answered 2026-06-26

Disclosure – Template EU CQ4: Treatment of cash balances at central banks and other demand deposits

Answered 2026-06-05

Disclosure of liquidity requirements - NSFR - LIQ2. Periodic data to be disclosed in the Disclosure Period

Answered 2025-10-31

Clarification on column a) "Total exposures", CR7-A Template

Answered 2025-10-31

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

Answered 2025-10-10

📋 Track EU financial regulation continuously

Forseti monitors EU financial regulation and delivers personalised alerts anchored to verified official sources.

Start free trial → Learn more

14-day free trial. No credit card required.