ESG P3 - Template 1, 5 and 7 disclosure of subsidiaries, joint venture and associates

Does Equity instruments to be reported in Pillar 3 ESG tables include also investment in subsidiaries, joint ventures and associates?

According to REGULATION (EU) 2022/2453 of 30 November 2022 on ESG risks for the purpose of the feeding of Template 1 – Banking book – Indicators of potential climate change transition risk “Institutions shall include in the rows of the template the breakdown of the gross carrying amount of loans and advances, debt securities and equity instruments to non-financial corporations, other than those held for trading, ….”. The mentioned regulation defining the Gross Carrying amount makes express reference to FinRep  Annex V “Institutions shall disclose the gross carrying amount, referred to in Part 1 of Annex V to Implementing Regulation (EU) 2021/451, of those exposures towards non-financial corporates, including loans and advances, debt securities and equity instruments, classified in the accounting portfolios in the banking book in accordance with that Implementing Regulation, excluding financial assets held for trading or held for sale assets.” In particular, reference is made to loans and advances, debt securities and equity instruments, classified in the accounting portfolios in the banking book that according to FinRep Annex V “shall not include investments in subsidiaries, joint ventures and associates, balances receivable on demand classified as ‘Cash, cash balances at central banks and other demand deposits’, nor financial instruments classified as ‘Held for sale’ presented in the items ‘Non-current assets and disposal groups classified as held for sale’ and ‘Liabilities included in disposal groups classified as held for sale’.” However, within DPM table layout and data point categorization updated on October 30, 2023 (i.e. EBA annotated table) , the reference to the Accounting portfolios to be reported is as such: “Accounting portfolio for financial assets other than trading or held for sale, including Investments in subsidiaries, joint ventures and associates”. Thus including also equity instruments reported in FINREP table F1.1 row 260.                          This contradiction applies also to all other ESG tables requesting to report “Equity instruments” including GAR table (templates 7/8), which should represent all equity instruments with Credit Institutions, Other Financial Corporations and Other Financial Corporations. Whilst from an ESG perspective we acknowledge the need to collect and report information on Taxonomy eligibility and alignment even for this category of counterparties, we believe that presenting them within the Equity instruments might be confusing especially when reference is made to accounting portfolios.  Therefore we seek clarification on how to report this information.