EBA · 2024_7225 Final Q&A

ESG P3 - Template 1 - Reporting of column k (GHG emissions (column i): gross carrying amount percentage of the portfolio derived from company-specific reporting)

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
449a
Topic
Transparency and Pillar 3
Submitted by
Other
Submitted
2024-10-18
Answered
2025-04-11
Answer provided by
ESAs (EBA, ESMA, EIOPA)

Question

In Template 1, “ column k (GHG emissions (column i): gross carrying amount percentage of the portfolio derived from company-specific reporting)”,  should the denominator used in the calculation of the percentage be: the gross carrying amount of exposures which GHG emissions are available or estimated  OR the gross carrying amount of all the exposures within the banking book portfolio regardless of whether the GHG emissions are available, estimated or not available (missing).

Background

According to the ITS, Template 1 reports exposures towards non-financial corporates, including loans and advances, debt securities and equity instruments, classified in the accounting portfolios in the banking book excluding financial assts held for trading or held for sale assets.  The instructions given for the “column k (GHG emissions (column i): gross carrying amount percentage of the portfolio derived from company-specific reporting)”  of Template 1   is that: “Institutions shall indicate the percentage of the portfolio (gross carrying amount of the exposures)  for which they have been able to estimate their counterparties’ scope 1, 2 and 3 emissions  associated with institutions’ lending and investment activities based on information disclosed by their counterparties or reported to the institution on bilateral basis”   For exposures to counterparties without scope 1, 2 and 3 emissions data (no reported amount, neither estimation / missing) , these exposures will not have data reported in “ column i (GHG financed emissions (scope 1, scope 2 and scope 3 emissions of the counterparty) (in tons of CO2 equivalent) ”. So, for the calculation of column k, can you please clarify whether the gross carrying amount of these exposures should to be included in the denominator for the calculation of percentage (as they are still part of the Banking Book portfolio) or to be excluded ?   Example: assuming both of these 2 exposures are part of the portfolio of Banking Book in scope for Template 1 reporting: Exposure Gross Carrying Amount GHG emissions reported or estimated Exposure 1 100 Yes Exposure 2 200 No The denominator i.e. gross carrying amount used in the calculation of the percentage for column k will be based on 100 or 300?

Answer

The denominator used for the calculation of the percentages disclosed in column k of Template 1 of Annex XXXIX of Regulation (EU) 2021/637 should include exposures without GHG emissions reported or estimated. Following the example provided above, the denominator should be 300 in that case.

Original source: European Banking Authority, Q&A ID 2024_7225

This Q&A is published by European Banking Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

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