Template 2 - EBA val rules and Column 0160 Of which level of energy efficiency EP score in kWh_m of collateral estimate

Question 1 : Are the validation rules v16092_m; v16090_m; v16088_m; v16086_m; v16084_m;v16082_m; v16080_m; v16078_m; v16049_m correctly defined?    Question 2 :  How to deal with exposure for which and EPC is available, but the Level of energy efficiency (EP score in kWh/m² of collateral) is absent from the EPC?

Question 1: By strictly applying the EBA validation rules, it is impossible to be successful unless having 0% for “Of which level of energy efficiency (EP score in kWh/m² of collateral) estimated”.  Note also the answer of EBA Q&A­_ 2022_6625 is not aligned with the EBA validation rules, an example to highlight: EBA validation rules v16084_m for row 020: {D 02.00.a, c0010} = ({D 02.00.a, c0020} + {D 02.00.a, c0030} + {D 02.00.a, c0040} + {D 02.00.a, c0050} + {D 02.00.a, c0060} + {D 02.00.a, c0070} + {D 02.00.a, c0150}) * (1 - {D 02.00.b, c0160}). Here the entire sum of columns 20+30+40+50+60+70+150 must be multiplied by (1 - {D 02.00.b, c0160}) EBA Q&A­_ 2022_6625: Column A in Template 2 of Annex 1 to Implementing Regulation (EU) 2022/2453 should be the sum of columns from B to G + (O * (1 - P)) . Here only the Column 150/row20 must be multiplied by (1 - {D 02.00.b, c0160})   Question 2: Until 31/12/2020, the EPC regulation NEN 7120 in The Netherlands was providing an energy performance label but was not providing any kWh/m2 energy consumption.  Since the 01/01/2021, the new EPC regulation NTA 8800 in place in the Netherlands is providing an energy performance label AND the kWh/m2 energy consumption. It means we can have a real situation where an EPC is available but without any information on kWh/m2 energy consumption. This situation can have an impact on the supposed correct validation rules proposed in EBA Q&A­_ 2022_6625: See example 4 in the attached file: if we consider that the kWh/m2 energy consumption is internally estimated by the bank, we failed with validation rules proposed in EBA Q&A­_ 2022_6625 See example 5 in the attached file: if we consider that the kWh/m2 energy consumption is NOT internally estimated by the bank (= is coming from the EPC), we success with validation rules proposed in EBA Q&A­_ 2022_6625