EBA · 2025_7633 Rejected question

Template 2 - EBA validation rules v89325_m and v89326_m

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
449a
Topic
Transparency and Pillar 3
Submitted by
Credit institution
Submitted
2025-11-24

Question

The formula linked to the following rule IDs: v89325_m and v89326_m appears to be incorrect

Background

These rules imply that the amounts reported in row 0010 “ Total EU area ” and row 0060 “ Total non-EU area ”  should be greater than or equal to the sum of rows 0020, 0030, 0040, 0050 and 0070, 0080, 0090, 0100 respectively, across the specified columns. However, according to the template instructions, row 0050 and 0100 represent “ Of which Level of energy efficiency (EP score in kWh/m² of collateral) estimated ”, which is an additional breakdown for the extent to which these data are estimated and not based on EPC labels, and as per our understanding are not part of the aggregation logic for rows 0020–0040 and 0070-0090 respectively. We therefore believe the validation rules should exclude row 0050 and 0100, as its inclusion appears to contradict the template’s design and instructions.
No answer published yet.

Original source: European Banking Authority, Q&A ID 2025_7633

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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