Calculation of the GAR and BTAR flow versus the previous disclosure period

For Small and Non Complex Institution and other institution, should the GAR and BTAR flow be calculated on a semi-annual or an annual basis?

CRR3 approved by EU parliament on 24/04/2024 indicates: Art 433a: Disclosures by large institutions: article 449a (=Disclosure of environmental, social and governance risks (ESG risks)), to be disclosed on a semi-annual basis   Art 433b: Disclosures by small and non-complex institutions: article 449a (=Disclosure of environmental, social and governance risks (ESG risks)), to be disclosed on annual basis   Art 433b: Disclosures by other institutions: article 449a (=Disclosure of environmental, social and governance risks (ESG risks)), to be disclosed on annual basis   Template 8 GAR % flow: “Proportion of new assets funding taxonomy relevant sectors Institutions shall disclose the proportion of new assets ( i.e. assets originated within the current disclosure period ) funding taxonomy-relevant activities (i.e. eligible assets) for the objective of climate change mitigation in total new eligible assets (i.e. eligible assets originated within the current disclosure period). New assets shall be calculated net of repayments and other reductions. Tis item shall be expressed as in percentage terms.”     Template 9.2 BTAR: “Institutions may disclose in this template the percentage of BTAR assets as disclosed in template 1 compared to the total assets in the denominator of the BTAR as disclosed in row 17 of template 9.1.” It is the only instructions available. In this template columns 0170 to 320 are dedicated to KPIs on flow. Even if there is no details instructions available, we interpret that the Institutions shall disclose the proportion of new assets (i.e. assets originated within the current disclosure period) funding taxonomy-relevant activities as per template 8 GAR % flow instructions.   By strictly following the CRR3 adopted and the (EU) 2022/2453, it means the flow should be calculated on an semi-annual basis for large institution and on annual basis for any institution which is not large.   The attention point is that ultimately, the GAR flow % and the BTAR% flow won’t be comparable between institutions if they are using different disclosure frequency to calculate them, while one of the spirit of the public disclosures is to enable comparison between institutions.   The only option available to avoid this misalignment would be to force any institution which is not large to disclose on a semi-annual basis, which would not be compliant with the official regulation.