EBA · 2025_7424 Rejected question

BTAR voluntary disclose and DPM templates

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
ANNEX XL - Instructions for disclosure of ESG risks, para. Template 9 - Mitigating actions: BTAR
Topic
Transparency and Pillar 3
Submitted by
Consultancy firm
Submitted
2025-04-23
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Question

Regarding the generation of DPM templates containing ESG pillar 3 disclosure, included in reporting framework 3.3 for the ad-hoc collection, according to Commission Implementing Regulation (EU) 2022/2453, template 9 – Mitigating actions: BTAR- was required for December 24 submission only on a voluntary basis.  In case a bank has decided not to publish BTAR template in the Pillar 3 disclosure for December 2024, our understanding is that there is no obligation to deliver, for December 2024, these templates (D 09.01, D 09.02.a, D 09.02.b, D 09.02.c, D 09.02.d, D 09.03.a, D 09.03.b) included in reporting framework 3.3 to keep both reports aligned (Pillar 3 disclosure, made public in February 2025, and the reporting framework 3.3 templates). Please confirm that our view on this subject is correct.

Background

The decision not to disclose the Pillar 3 ESG Templates 9 (BTAR) was taken by the bank in light of the voluntary reporting of the aforementioned documents. In addition to the public disclosure, these templates are to be reported in the Reporting Framework 3.3 and should be aligned with each other.
No answer published yet.

Original source: European Banking Authority, Q&A ID 2025_7424

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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