EBA · 2023_6708 Final Q&A

ESG P3 - Reg 2453/22 - Scope of application

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
449a
Topic
Transparency and Pillar 3
Submitted by
Competent authority
Submitted
2023-01-30
Answered
2023-08-25
Answer provided by
ESAs (EBA, ESMA, EIOPA)
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Question

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

Background

Article 449a CRR states that: "large institutions which have issued securities that are admitted to trading on a regulated market of any Member State, as defined in point (21) of Article 4(1) of Directive 2014/65/EU, shall disclose information on ESG risks". In the EBA/ITS/2022/01 we found the following clarification: "Institutions should disclose the information at the highest level of consolidation consideration in the EU, as regulated in Article 13 CRR." (page 52) Due to the above, there is different understanding of the scope of application of the ITS on Pillar 3 ESG disclosures, both between banks as well as the regulator. Shall all large listed institutions in a jurisdiction disclose the P3 ESG information (this means disclosure on subconsolidated basis for some banks) or only large listed institutions which are the EU highest parent institutions (this significantly reduces the number of banks subject to the Reg. 2022/2453 in PL).

Answer

As clarified by the EBA/ITS/2022/01, institutions should disclose the information at the highest level of consolidation in the EU, as regulated in Article 13 CRR. For the detailed information on scope of application of Article 449a CRR please refer to QA2022_6652.

Original source: European Banking Authority, Q&A ID 2023_6708

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.

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