GAR template 7, row 25 Households

For GAR template 7, must the row 24 “households” be always strictly equal to the sum of rows 25 +26 + 27?

This question is applicable to row 24 for columns a, b, c, d, e, and f Q&A 2023_6780 indicates: “According to Annex V., 1.2.1.3 of the Regulation (EU) 2021/2178, the Green asset ratio for retail exposures shall apply only to investments relevant for climate change mitigation . Template 7 - Mitigating actions: Assets for the calculation of GAR of the Regulation (EU) 2022/453 (ITS on ESG disclosures) do not foresee a specific line to report Households exposures other than the ones included in the template (loans collateralised by residential immovable property, building renovation loans, motor vehicle loans). As a consequence, institutions should report such exposures in Template 7 either in row 24 in case they are considered covered assets in both numerator and denominator of the GAR, or in row 44 “Other assets” in case they are excluded from the numerator but covered in the denominator of the GAR.”   By reading “the Green asset ratio for retail exposures shall apply only to investments relevant for climate change mitigation ” and because to our knowledge all economical activities applicable to households and related to “investments relevant for climate change mitigation” are included into row 25 + 26 +27, we derive row 24 is always the sum of row 25+26+27. This interpretation is confirmed by reading REGULATION (EU) 2021/2178 section 1.2.1.3. Green asset ratio for retail exposures.   But this interpretation could be incorrect if EBA expects for instance to have household Credits for consumption for buying TV, Fridge, travel package, etc. in row 24, because they are not in scope of climate change mitigation. Moreover, Draft Commission Notice 21 December 2023 (  https://ec.europa.eu/finance/docs/law/231221-draft-commission-notice-eu-taxonomy-reporting-financials_en.pdf ) on paragraph 56 page 43 states that ’’the gross carrying amount of each reported instrument should perfectly match the one reported in FINREP’’. In this case household Credits for consumption for buying TV, Fridge, travel package, etc. should be reported in row 24 and then this row 24 won’t be the sum of row 25+26+27.   NB: we know there is no EBA validation indicating that row 24 must be the sum of rows 25 +26 +27. We would warmly welcome the reasoning behind.