Interpretation of "exposures attributable to a central government" set forth in Article 400 (1)(d) of CRR

In the context of the application of Article 400 (1)(d) of CRR, which sets forth the types of exposures that shall be exempted from the application of Article 395 (1) of CRR, what exposures shall be considered to be attributable to the central government? May a financial institution exempt exposures to state-owned enterprises that i) provide public services, ii) the economic activities of which are subsidized by the state, iii) where the transfer of financial resources is based on legislative arrangements, provided that such exposures - if they were to exist to the central government, that is the entity to which the exposure is attributable, would be assigned a 0 % risk weight under Part Three, Title II, Chapter 2 of CRR? May the application of Article 400(1)(d) be triggered by demonstrating that there is a risk equivalence between exposures to such state-owned enterprises and exposures to central governments?

Our client is a commercial bank (hereinafter: the Client) that keeps records of exposures to an enterprise that is solely owned by the Hungarian State, with the ownership rights exercised by a Hungarian Ministry. The enterprise is part of the national property according to the Hungarian Act on National Property. The enterprise is a holding company, its subsidiaries are engaged in the sale of electricity and the exclusive supply of natural gas to the public for the purpose of ensuring the fulfillment of the public tasks of the Hungarian State. The designated Ministry exercises its ownership rights in accordance with the provisions of the Hungarian Act on National Property, thus preserving at all times the basic purpose of the national assets, i.e. the provision of public services, including the provision of public services to the population and the provision of the infrastructure necessary for the performance of these services. The enterprise in question is part of the National Strategy and Energy Action Plan for the provision of public services pursuant to Hungarian Government Decree 110/2020 (IV.14.) and the Emergency Plan for the Security of Natural Gas Supply in Hungary (in accordance with the provisions of Regulation (EU) No. 2017/1938). The Hungarian State grants non-refundable subsidies to the enterprises in question to carry out their activities pursuant to Government Decree No 289/2022 (5.7.22), compensating any losses incurred in connection with the enterprises' sales activities and ensuring the continuation of the enterprises' operations. The compensation is I) paid on the basis of a contract concluded between the enterprises and the Ministry (Minister) exercising the ownership rights, pursuant to Government Decree No 289/2022 (5.7.2022), and ii) charged to the central budget. The enterprises in question are accountable to the Hungarian State.