Response to discussion on Technical Advice on selected KPIs under the Taxonomy Disclosures Delegated Act under Article 8 of the Taxonomy Regulation
Q1. Please identify your organisation (if applicable) and indicate the capacity in which you are responding to this consultation:
d. other (please specify)Other (please specify)
Audit firmQ2. Do you agree with the analysis presented?
Yes, we generally agree with the analysis presented.
In your response, where applicable, please assess whether voluntary disclosure of this KPI would be meaningful and feasible, and hence should be considered.
We support removing the Fees and Commissions KPI from the disclosure requirements (i.e. View A), without replacing it with qualitative disclosure requirements. Only in case some credit institutions would find it relevant and useful, we would support the possibility of voluntary qualitative disclosures.
Q4. Should additional items from FINREP Template 22.1 also be included in the revised KPI? Please consider in particular that (i) have been assessed as unrelated to capital market activities, e.g. ‘custody and other related services’, and (ii) those that have not been mapped to the Fees and Commissions KPI, such as ‘structured finance’, ‘loans granted’, ‘commodities’.
Not answered
Q5. Do you have evidence and/or arguments on potential costs and benefits associated with disclosing the Fees and Commissions KPI?
Not answered
Q6.Do you agree with the analysis presented?
Yes, we generally agree with the analysis presented.
In your response, where applicable, please assess whether voluntary disclosure of this KPI would be meaningful and feasible, and hence should be considered.
We support removing the Trading Book KPI from the disclosure requirements (i.e. View A), without replacing it with qualitative disclosure requirements. Only in case some credit institutions would find it relevant and useful, we would support the possibility of voluntary disclosures.
Q8. Do you have evidence and/or arguments on potential costs and benefits associated with disclosing the Trading Book KPI?
Not answered
Q9. Do you agree with the analysis presented and the conclusion to narrow down the investment firms’ KPI?
Not answered
Please explain if you think that other services, e.g. execution of orders on behalf of clients, should be included in the revised KPI.
Not answered
Q11. Do you consider it more appropriate for the KPI to reflect the value of assets covered by the investment services rather than the monetary benefits generated?
Not answered
Q12. Do you agree with the analysis presented and the conclusion to align the grandfathering rules with the approach set out in EU Green Bond Regulation?
Not answered
Q13. Do you agree with the analysis presented and proposed conclusions?
Not answered
i. Should the KPI disclosed by the parent undertaking, reflecting the group’s main or prevalent activity, be used? If not, what alternative methodology should be applied?
We agree with the ESAs on the fact that the weighted average KPI introduced by the European Commission Notice C/2024/6691 is generally not relevant. And where a single KPI is required for the parent undertaking of a group, we agree that the KPI disclosed by the parent undertaking, reflecting the group’s main or prevalent activity, should be used. Moreover, we support keeping the current approach based on aligning the calculation of the KPIs of credit institution-led groups with the prudential scope, in order to avoid introducing new areas of complexity.
ii. In the case of a credit institution-led group, such as a financial conglomerate, should the consolidated KPI disclosed by the parent undertaking also incorporate the assets of the insurance (and non-financial) undertaking, rather than accounting for the insurance (and non-financial) undertaking solely through the equity method? Please justify your answer in terms of feasibility, usability and transparency of sustainability information.
In line with our response above, we support keeping the current approach based on aligning the calculation of the KPIs of credit institution-led groups with the prudential scope, in order to avoid introducing new areas of complexity.
Q15. Which KPIs you do think are necessary and should be required for groups with mixed activities where the credit institution is the parent company such as credit institution-led financial conglomerates, credit institution-led financial holding companies and relevant mixed financial holding companies?
We are of the view that the taxonomy reporting of a credit institution-led group with mixed activities should be presented using the templates set for credit institutions in accordance with Annex V of Commission Delegated Regulated Regulation (EU) 2021/2178. In addition, whenever deemed relevant and taking into account financial undertakings’ information needs, the contextual information accompanying the taxonomy reporting could include, in a summarized format, the main KPIs determined at the level of the main different sectors of that group (insurance, asset management, non-financial activities, …), following the requirements applicable to those sectors KPIs – to the extent that such sectors are material within the group and this would lead to the presentation of material differences in the level of alignment for the KPIs presented. However, there should be no expectation created that a complete set of templates for each of the sectors of groups with mixed activities should be included.
Q16. Do you agree with the analysis presented and the conclusion that OpEx financing should not be explicitly incorporated in the methodology for calculating financial undertakings’ KPIs? Please provide your rationale for supporting the explicit inclusion of provisions allowing financial undertakings, on a voluntary basis, to use the OpEx KPI disclosed by their counterparties when calculating their own KPIs.
We agree with the analysis presented and the conclusion that OpEx financing should not be explicitly incorporated in the methodology for calculating financial undertakings’ KPIs.
Q17. Should the credit institution’s AuM KPI (Annex V) and the KPI for asset managers (Annex II) be merged? Please explain why and how, including the content of the information that should be retained in a potential merged KPI.
Not answered
Q18. What are your views on the design of off-balance sheet item reflecting financial guarantees to financial and non-financial undertakings in a potential merging of the asset management activities as presented?
Not answered
Q19. Do you have any additional comments or suggestions to improve, simplify or clarify the disclosure requirements within the scope of this Call for Advice, including through redrafting of instructions, and clarification of definitions, or the streamlining of terminology?
Not answered