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).

In the Annex II of the Commission Implementing Regulation (UE) 2022/2453 of 30 November 2022 is stated that: “This template covers other climate change mitigating actions and includes 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, including green bonds; sustainable bonds that are linked to aspects on climate change; sustainability-linked bonds that are linked to aspects on climate change; green loans; sustainability-linked loans that are linked to aspects on climate change; sustainability-linked loans that are linked to aspects on climate change”. The interpretation of this statement could be debatable regarding the perimeter of the exposures (Bond and Loan) that institutions shall select for the Template 10 disclosure. The institutions may interpret the reference to the Templates 7 and to the Template 8: “not taxonomy-aligned as referred to in Regulation (EU) 2020/852 according to templates 7 and 8” as whether the consequent process to select the exposure to be included in the Template 7, 8 and 10 is the following: select eligible exposures and then report exposure taxonomy-aligned in Template 7/8 while exposure not taxonomy-aligned in Template 10 (option A). However, the Annex II statement could also be interpreted in a different way: in Template 10 should be reported not only exposures that are eligible but not taxonomy-aligned (therefore not included in Template 7/8 – as in option A), but also exposures that are not eligible but are considered environmentally sustainable nevertheless (giving evidence of the standard followed for the environmentally sustainable evaluation) – option B.