Response to consultation on Implementing Technical Standards on amended disclosure requirements for ESG risks, equity exposures and aggregate exposure to shadow banking entities

1. Do you have any comments on the proposed set of information for Large institutions?

We would like to highlight the duplication of disclosures for institutions that fall under the scope of the CSRD. EU Taxonomy (EUT) templates are already required under CSRD, and duplicating these in the Pillar III ESG reporting framework adds unnecessary burden without delivering additional value. With the planned tagging of EUT data, access to this information will become even more straightforward, making the case for duplicate reporting even weaker. In light of this, we propose that the EUT templates be removed from Pillar III reporting altogether.

Alternatively, the EBA could coordinate with the European Commission to move the relevant EUT templates into Pillar III, so that institutions only report this information once. This could be considered in the context of the upcoming Article 8 review. It's also worth noting that duplication is not limited to quantitative templates, as qualitative disclosures are affected as well. We have provided detailed feedback on those overlaps in our responses to the final set of questions.

2. Do you have any comments on the simplified set of information for Other listed institutions and Large subsidiaries?

A simplified set of reporting for Large subsidiaries and Other listed institutions is welcomed and in line with the aim to reduce overall reporting burden for entities in scope. However, consistency with reporting requirements of Large institutions is essential. Indeed, the simplified data set should not include data points not already collected and disclosed by the parent large institutions as this would: 

• Add to administrative and operational burden;
• Create inconsistency and lack of comparability between the disclosure of the subsidiary and its parent. 

In the current draft proposal of template 5 and 5a, there are inconsistencies (NUTS 3 level versus NUTS 2 level) which should be resolved. 

3. Do you have any comments on the simplified set of information proposed for SNCI and other non-listed institutions?

Not applicable to large institutions and large subsidiaries - no comments.

4. Do you have any comments on the proposed approach based on materiality principle to reduce the frequency (from semi-annual to annual) of specific templates (qualitative, template 3, and templates 6-10) for large listed institutions?

The EBA Guidelines on materiality, proprietary and confidentiality and on disclosure frequency  requires the materiality assessment to be linked to qualitative characteristics such as activities and risk profile of the institutions. Therefore, a materiality-based approach is subjective and would not enhance comparability between banks. 

In addition, the execution of a periodic materiality assessment to determine reporting frequency would not be a relief of burden considering the extensive assessment required as well as the need for proper governance around such assessment. While in theory changing a reporting frequency might seem simple, in practice the simple change of reporting frequency due to materiality assessment requires mobilization of workforce, update of processes (to move from yearly to semi-annual), update of the governance, etc. 

To finish, based on the content of the templates and the reporting experience of the past years, semi-annual reporting of these templates has limited to no additional value: 

• Template 3 targets are set on an annual basis, reporting on semi-annual basis does not provide additional or new information (as also mentioned in article 29 of the consultation paper). This is also in line with the Q&A 2023_6859 which requires institutions to update and recalculate the value of the alignment metric on an annual basis.
• Regulation 2021/2178 (EUT Art 8) requires yearly reporting. As a result, semi-annual disclosures in Pillar 3 ESG would not be aligned with EUT article 8 requirements, nor the aim to reduce reporting burden for companies in scope. In addition:
• The templates 1 & 4 Annex VI of EUT Art 8 required for disclosing templates 7 & 8 are not available for semi-annual reporting.
• Semi-annual reporting of EUT templates requires a significant effort from reporting companies while providing limited insights due a.o. to the fact that EUT KPIs of counterparties are only available on an annual basis.
• Due to the interoperability of the templates 9 and 10 with the GAR and BTAR templates, the frequency of these templates should be aligned (as mentioned in article 29 of the consultation paper).

Proposal: Remove the materiality principle and amend the reporting requirement of templates 3 and 6-10 to annual reporting frequency without any conditions.  Based on the nature of these templates, such frequency would be sufficient for the users of the information.

5. Do you have any comments on the transitional provisions and on the overall content of section 3.5 of the consultation paper?

Due to the ongoing Omnibus proposal, the temporary suspension of reporting templates 6-10 until end 2026 is welcomed. 

To further support the transitional provisions, a ‘no action letter’ stating that competent authorities should not prioritize any supervisory or enforcement action would be welcome, like the letter EBA published concerning the Market Infrastructure Regulation.

We noted that while EU Taxonomy alignment disclosures are also required in the templates 1 and 4 in the column ‘of which environmentally sustainable CCM’, they are not covered by the transitional provisions. For consistency purposes it is requested to clarify that the transitional provision also applies to the EUT-related information in templates 1 and 4. 

Proposal: 

• Maintain the transitional provisions but supplement with a ‘no action letter’ issued by EBA.
• Extend transitional provisions to EUT information reported in templates 1 and 4.

[at the time of submission, the EBA has not published the no-action letter]

6. Do you have any comments on the proposed amendments to Table 1 and Table 3?

No comments other than the issue on duplication of information covered in the last question of the questionnaire for the ESG section. 

7. Do you have any further suggestions on Table 1A?

Not applicable to large institutions and large subsidiaries - no comments.

8. Do you have any comments on the proposed additions and deletions to the sector breakdown?

No comments.

9. Do you have any views with regards to the update of the templates to NACE 2.1?

No comments.

10. Do you have any views with regards to NACE code K – Telecommunication, computer programming, consulting, computing infrastructure and other information service activities, and in particular K 63 - Computing infrastructure, data processing, hosting and other information service activities, whether these sectors should be rather allocated in the template under section Exposures towards sectors that highly contribute to climate change?

No comments.

11. Do you have any comments on the inclusion of row “Coverage of portfolio with use of proxies (according to PCAF)”?

We welcome the addition of such row in template 1 as it increases transparency of the information. 

12. Do you have any further comments on Template 1?

Presentation of GHG financed emissions

Revised template 1 introduces two new columns for a separate reporting of scope 1 and scope 2 GHG emissions (in column i1 and i2 respectively). In our view, the reporting could be simplified by reporting scope 1 and 2 in a combined way under one column rather than disclosing these separately. Indeed, in practice, companies within the same sector might report energy consumption related emissions in their scope 1 or 2 depending on whether they have energy production unit on-site or off-site. Classification between scope 1 and 2 is therefore solely driven by business model and operational choices while the emissions are related to the same purpose (i.e. running day-to day business). Such split does not provide additional benefits. This position is also supported by the fact that PCAF guidelines, as well as GHG Protocol, recommends the disclosure of scope 1 and scope 2 financed emissions in a combined way (unless disclosing separately serves the financial institutions’ business goals)[1]. 

In addition, to avoid duplicating disclosures, we propose to remove the column “GHG financed emissions (scope 1, scope 2 and scope 3 emissions of the counterparty) (in tons of CO2 equivalent)”. Aggregating scope 1/2/3 is also not appropriate as (1) it mixes different emission profiles, i.e. scope 1+2 reflects operational exposure under direct control while scope 3 is a value chain exposure; (2) double counting is inherent in GHG accounting however aggregating all three scopes makes it worse, i.e. scope 1+2 of company x, which appears in scope 3 of company y, is counted again under total scope 1+2+3 emissions when all aggregated; (3) data quality of scope 1+2 and scope 3 emissions vary significantly.

Proposal: 

• Combined reporting of scope 1 and scope 2 GHG emissions into one column for a simplified reporting consistent with relevant existing frameworks (GHG protocol and PCAF guidelines).
• Remove column ““GHG financed emissions (scope 1, scope 2 and scope 3 emissions of the counterparty) (in tons of CO2 equivalent)”.

Scope 3 financed emissions reporting for ‘material’ sectors

Revised ITS on template 1 states that “Institutions are expected to disclose scope 3 emissions for all material sectors”. We are concerned that introducing a materiality approach without further guidance may impair comparability between banks, given the inherent subjectivity in determining materiality.  

In addition, the ITS should clearly state that Institutions should consider the entire full value chain of their counterparties (upstream and downstream), in line with the GHG Protocol, for their scope 3 calculation and explain any deviation (e.g. narrative on part of the value chain covered). This ensures that companies that cover a broader part of the value chain are not at a disadvantage by showing larger emissions.

Proposal: 

• Provide further guidance on the materiality principle.
• Clarify in the instructions that full value chain of the counterparties should be disclosed, or deviation should be explained in the narrative.

[1] PCAF Financed Emissions Standard, 2^nd Edition December 2022, p. 125

13. Do you have any comments or alternative suggestions for SNCIs and other institutions that are not listed, regarding the sector breakdown?

Not applicable to large institutions and large subsidiaries - no comments.

14. Do you have any additional suggestions how to adjust Template 1A for SNCIs and other institutions that are not listed?

Not applicable to large institutions and large subsidiaries - no comments.

15. Do you have any further comments on Template 1A?

Not applicable to large institutions and large subsidiaries - no comments.

16. Should Template 2 in addition include separate information on EPC labels estimated and about the share of EPC labels that can be estimated?

No, EPC labels should not be estimated. Methodologies in relation to EPCs are not harmonized between different jurisdictions and it may require significant operational burdens, especially for banks operating globally. In any case, banks can estimate energy performance scores and include in under column b to g.

17. Should rows 2, 3 and 4 and 7, 8 and 9 for the EP score continue to include estimates or should it only include actual information on energy consumption, akin to the same rows for EPC labels?

EP scores should continue to include estimates, as estimation of EP scores can be done relatively reliably while complementing data gaps and providing additional context for buildings without EPC label. In addition to this, estimations are the only alternative in certain jurisdictions due to the (local) GDPR considerations. Therefore it is beneficial to keep estimations in the context of EP scores.

18. Do you have any comments on the inclusion of information on covered bonds?

Reporting obligations related to covered bonds are already addressed under the EU Covered Bond Directive (Directive 2019/2162). This directive establishes the regulatory and transparency requirements for covered bonds, including investor protection mechanisms and disclosure standards. It would not be operationally efficient for investors to get part of covered bonds information via EU covered bond directive disclosures and the ESG related information as part of Pillar 3 disclosures. In addition, the frequency of disclosures differs (quarterly versus semi-annually).  In addition to that, ESG-related information on covered bonds can already be provided through existing market channels, such as harmonized transparency templates and regular investor reporting. To avoid fragmenting reporting which would reduce clarity for investors, the ESG related information should be embedded in the dedicated covered bonds reporting tools. 

In addition, it is unclear what is the exact goal for the introduction of such row within Pillar 3 disclosures -risk related disclosures. If the goal is to enhance transparency of funding risk related to environmental quality of the collaterals, it raises the question whether it makes sense to only disclose information on covered bonds and not include securitization vehicles.

Proposal: 

1. Remove the row “covered bonds” from template 2 to avoid fragmented disclosures.
2. If the row is kept in this template, clarify the intent to introduce such information in a risk related disclosures as well as investigate whether securitization vehicles should also be included in template 2.

19. Do you have any comments on the breakdown included in columns b to g on the levels of energy performance?

Column b of the template, which captures the energy performance score ranging from 0 to 100, could be further split it into two buckets. Introducing a 0–50 range would better identify (near) net-zero homes, providing more granular insights into the evolution of housing stock in the context of transition efforts. In addition, other EP score buckets can also be split to enhance granularity and insights.

20. Do you have any further comments on Template 2?

No additional comments.

21. Do you have any comments on Template 3?

Sectors (column a)

The revised ITS expects banks to disclose indicators of potential climate change transition risk, i.e. emission intensity per physical output for each of TCFD 18 sectors if deemed material. Such requirements raise several concerns that should be taken into consideration before finalization of the ITS:

• As per EBA GL on ESG risk management, institutions are given flexibility to determine their own combination of tools for assessing and managing ESG risks based on their business characteristics. Hence, they are not required to set up GHG intensity metrics per physical output to manage their transition risk solely. Requiring institutions to disclose such GHG intensity metrics for all material sectors regardless of their internal use for risk management purpose would increase the burden for banks and could be potentially misleading as this metric would be only used for reporting purposes. 

  Proposal: Clarify that banks should only provide GHG intensity metrics when it is established for internal risk management purposes, including monitoring.

• Sector breakdown: At this stage, the draft ITS refers to TCFD which is a task force that has been dismantled.  We believe an operational efficiency could be achieved by considering either: (1) providing full flexibility to banks in determining sectors and sub-sectors based on their internal models – which can be more insightful based on specific business characteristics of banks; or (2) providing prescriptive guidance on sector level what needs to be covered – in order to ensure the level playing field and comparability. Any other option that remains between the flexible and prescriptive approach will be burdensome with highly limited comparability.

  Proposal: Require either a full flexible approach where sectors are determined by banks or impose a prescriptive list of sectors to ensure operational efficiency. 

• Materiality: If a materiality-based approach remains, at minimum EBA should clarify whether the materiality threshold should be aligned with CSRD (i.e. disclosures directive) or EBA GL (i.e. internal risk management). Such clarity is key to ensure a similar treatment by the institutions. Alignment with the CSRD would be more appropriate to ensure a coherent approach between external reporting frameworks.

  Proposal: Clarify that materiality within P3 should be aligned with CSRD (i.e. disclosures requirements). 

GHG intensity metric per physical output (column d)

The revised ITS requires the disclosure of a GHG intensity metric per physical output. While we acknowledge that it is important to ensure standardization in terms of metrics, there are still practical challenges for certain sectors where such metric cannot be used for steering purposes – which can make reporting such metric a sole reporting exercise. 

For example, for sectors such as steel and shipping, banks may be able to calculate GHG intensity per physical output but cannot effectively steer on these metrics due to operational variability and process unpredictability. For these sectors, banks use frameworks that are largely adopted by the industry, such as Sustainable Steel Principles and Poseidon Principles, which use alignment delta to account for sector-specific variability. In such cases, a flexibility should be provided in the ITS to report an alternative alignment metric. 

Simplified example for the Steel sector:  For steering purpose and in line with the Sustainable Steel Principles, institutions are required to break down the global IEA pathway in 2 sub-pathways: one for 0% scrap metal and one for 100% scrap metal. The 2 pathways are then combined based on their portfolio average scrap metal to calculate the distance to 2030 IEA targets. For example, if for 2023 reporting, the average scrap metal for the portfolio is 70%, a weighted average of the 0% scrap metal and the 100% scrap metal pathways is performed to use an overall 70% scrap metal pathway. However, the year after, the average scrap metal can be significantly different (e.g. 30%) and the weighted average between the two pathways must be adjusted. Steering based on emissions intensity with such volatile mechanism is not feasible therefore institutions use the Sustainable Steel principles alignment delta for their internal risk management.

In addition, in the upstream oil and gas sector, many banks also monitor and steer their portfolios using absolute financed emissions. These metrics provide insights into net-zero strategies and can be used in alignment with IEA scenarios, where they exist. Therefore, the template should allow for the inclusion of these additional metrics if banks have formally set them. 

Proposal: 

1. Provide flexibility for disclosing absolute emission targets.
2. Provide possibility to disclose alternative metrics for sectors where steering on GHG intensity metric per physical output is not common market practice and alternative metrics used that are promoted by industry associations.
3. If such flexibilities are not introduced, create an additional column to indicate if the metric disclosed is used for internal risk management or not.

2030 Target for the value of intensity metric, according to IEA NZE2050 (Column h)

The IEA NZE2050 scenario offers global and sectoral pathways but does not provide institution-specific targets. It is the responsibility of each bank to derive its own 2030 target based on its portfolio composition and chosen methodology. Therefore, the datapoint name and definition should clarify that the 2030 target is a bank-specific value derived from the IEA NZE2050 scenario, or any other scenario in case IEA scenario is not available, rather than implying a direct figure from the IEA. 

In addition, it should also be clarified that banks are not required to recalculate their 2030 targets annually based on updated IEA NZE2050 datasets. Frequent recalculations would hamper the  stability of targets and long-term transition planning. This would result in unnecessary operational burdens considering the complexity of translating global IEA pathways into bank-specific targets. Instead, banks should be allowed to base their targets on a specific IEA dataset version, updating only when there are material changes in methodology or scenario assumptions. An additional column can be added to indicate the year of reference for the IEA dataset used. 

Proposal: Clarify that (1) Column h is a bank-specific value that is derived from IEA scenario, or any other scenario in case IEA scenario is not available; (2) Column h should not be calculated each and every year, unless there is a material change in the methodology and scenario assumptions, to ensure stability on targets and its steering.

22. Do you have any comments with the proposals on Template 4 and the instructions?

No comments.

23. Do you have any views on whether this template could be improved with some more granular information in the rows, by requesting e.g. split by sector of counterparty or other?

No comments.

24. Do you have any further comments on Template 4?

No comments.

25. Do you have any comments on the proposal using NUTS level 3 breakdown for Large institutions and NUTS level 2 for Other listed institutions and Large subsidiaries? Would NUTS level 2 breakdown be sufficient for Large institutions as well?

To ensure comparability and consistency between groups and large subsidiaries reporting, the geographical breakdown requirements between template 5 and template 5a must be aligned to avoid additional administrative burden.  In addition, using NUTS level 2 information for large institutions would enable a better comparability which will not be achieved with a NUTS 3 level of information (too granular).

Proposal: Adjust reporting requirements to NUTS 2 level for large institutions.

26. Do you have any comments on the instructions for the accompanying narrative and on whether they are comprehensive and clear?

No comments.

27. Do you have any further comments on Template 5 and on its simplified version Template 5A?

Large institutions are expected to disclose their top 10 NUTS level 3 geographical areas in terms of gross carrying amounts of exposures, as well as total EU exposures and total exposures. 

The proposed requirement for NUTS 2 or 3 level reporting is excessively granular, offering limited meaningful insights to users of the information and resulting in a lack of comparability across institutions. Therefore, we propose that reporting should only be done at total EU exposure and total exposure level.

If NUTS-level reporting is retained, it should be limited to known use of proceed collateralized loans, where geographical identification is feasible and meaningful. Indeed, for uncollateralized loans and in line with EBA GL, physical risk assessment is mainly performed using sector-level proxies and not actual physical locations. This is not solely due to the lack of asset-specific data, but also from usefulness to capture broader physical risk impacts across the value chain, where risks may materialize indirectly through suppliers, operations, or distribution networks. Hence NUTS-level reporting is not insightful for uncollateralized loans.

Proposal: 

(1) Solely require reporting at the total EU exposure and total exposure levels and remove NUTS level reporting.

(2) Include an additional column in total EU and total exposure templates to indicate whether the assessments is based on actual geographical data or sector-level proxies to provide insights into methodologies (e.g. % covered with actual geographical data, where remainder indicates sector level proxies); 

(3) If NUTS level reporting is retained, it should only be applicable to loans collateralized by immovable properties.

Our remarks are also applicable to Template 5A.

28. Do you have any comments on the proposal to fully align templates on the GAR, that is, templates 7 and 8, with those under the Taxonomy delegated act by replacing the templates with a direct cross reference to the delegated act?

Although we welcome alignment of the templates 7 & 8 with the EUT templates, considering the need for simplification we propose to remove these templates from P3 ESG reporting. There is no added value in reporting the templates under P3 ESG as: 

• The templates 6, 7 & 8 are a duplication of CSRD disclosures. In accordance with article  24 of the consultation paper, disclosure requirements already established in other applicable union law is to be avoided, however disclosing templates 6, 7 & 8 with P3 would duplicate information that is already required to be disclosed under CSRD and not aligned with the aim to reduce reporting burden (as part of published Pillar III reports and DPM).
• P3 ESG reporting is focused on providing risk information on ESG exposures however the templates 6, 7 & 8 disclose on financial information and do not include any risk information. The purpose of the templates 6, 7 & 8 is therefore not aligned with P3 ESG reporting. 

In addition, it should be noted that the current CSRD does not allow for EUT templates to be disclosed separately from the Sustainability Statement as “the disclosures relating to each of the environmental objectives defined in the Taxonomy Regulation shall be presented together in a clearly identifiable part of the environmental section of the sustainability statement”. Therefore, reference to Pillar 3 is not possible. Even if it were, the EUT information would be fragmented as the Pillar 3 disclosures do not cover all the EU templates.

If deletion of the EUT templates from Pillar III ESG disclosures is not considered, at minima, off-balance sheet exposures information should be excluded. Indeed, the cross-referenced EUT template includes off-balance sheet exposures whereas the remainder of Pillar III ESG disclosures exclude them. To maintain consistency across reporting framework and avoid misalignment with the rest of Pillar III ESG disclosures, off-balance sheet items should be explicitly removed from EUT reporting within Pillar III. 

Proposal: 

1. Remove the reporting requirement of the templates 6, 7 & 8 as it requires the disclosure of duplicative information and does not provide any valuable or additional risk information.
2. Off balance sheet items should be explicitly excluded from Pillar III disclosures. 

29. Do you have any comments on the proposal related the BTAR and to keep it voluntary?

While article 82 of the consultation paper states that BTAR information continues to be disclosed on a voluntary basis, the ITS was adjusted and now use the term “shall” instead of “may choose”. The draft ITS should be adjusted to reflect the voluntary nature of the BTAR. 

Consistency of the BTAR with the GAR templates is essential. While a first wave of amendments to EUT reporting expected to be finalized within Q2/Q3 2025 are already reflected in the draft ITS, a second wave of amendments is expected as a systematic and thorough review of the EUT article 8 disclosures by the EC is planned (timeline unknown). At this stage, it is unclear how the second wave of amendments will be reflected in the ITS to ensure consistence between the updated GAR and the BTAR. If such consistency cannot be achieved, it should be envisaged to delete the BTAR template.

To finish and in line with the Omnibus (draft delegated regulation amending Commission Delegated Regulation (EU) 2021/2178) proposal for EUT art 8 reporting, the EBA should explore the option of reporting on partial alignment within BTAR (e.g. meeting the substantial contribution criteria only).

Proposal:

1.  Amend draft ITS to ensure that BTAR disclosures remain voluntary (to avoid ambiguity).
2. Ensure that the latest upcoming GAR adjustments (timing unknown for the 2^nd wave of adjustments) are correctly reflected in the BTAR template to ensure consistency. If such consistency cannot be achieved, it should be envisaged to delete the BTAR template.
3. Explore the option to report partial alignment under BTAR. 

30. Do you have any comments regarding the adjustments to template 10?

Although there are some targeted improvements on Template 10, particularly regarding the first two columns, we recommend the following enhancements for more clarity and consistency:

• Further clarification could be achieved by providing definition of each row of template 10. Certain terms are not defined in existing reporting frameworks, such as ‘renovation loans’. Therefore, to increase implementation efficiency and comparability between banks, we recommend that the EBA includes specific instructions per row. In particular, for “renovation loans,” we recommend aligning the definition with that of “building renovations” as outlined in the Social Climate Fund (Regulation EU 2023/995). 

  Proposal: Provide detailed instructions/ definitions for each row of template 10.

• The revised ITS introduced ‘Of which: small and medium sized enterprises’ breakdown under loans and advances to non-financial corporations within Template 10. Such a breakdown is not part of the GAR and BTAR templates. To ensure simplification, as well as alignment between different templates, we recommend removing this breakdown. Note that, based on the current Excel layout, information on collateralized loans is presented as subset of this new breakdown on SMEs and not directly subset of ‘non-financial corporates’. It should be fixed if it is not intentional. 

  Proposal: Remove ‘of which: small and medium sized enterprises’ breakdown to ensure alignment with GAR and BTAR categories and achieve simplification.

• According to EBA Q&A 2023_6878, general purpose financing to pure-play companies can be reported under Template 10. We suggest that this clarification to be explicitly included in the revised ITS. In addition, to ensure consistent interpretation and application, a definition of pure player would be welcome.

  Proposal: Explicitly cover the pure player-related guidance provided in the ITS and provide a definition of ‘pure-player’ for consistent application among banks.

• As Template 10 focuses on assets contributing to sustainability and transition finance, it would be helpful to clarify whether and how financing provided to companies with credible transition plans that are on track to meet their targets should be reported within this template. This would contribute to the consistency of treatment and comparability on this matter. Please refer to ‘transition finance’ definition which touches upon this matter, on Commission Recommendation (EU) 2023/1425 of 27 June 2023 on facilitating finance for the transition to a sustainable economy, Section 2.2.

  Proposal: Provide clear guidance whether financing to companies with credible transition plans that are on track to meet their targets should be reported within this template. 

31. Do you have any further comments on the Consultation Paper Pillar 3 disclosures requirements on ESG risk?

• Referral to ‘Part I of the EBA IT solutions’ - A further clarification is needed on the amendment made in the ITS replacing all references to ‘Annex V of implementing regulation 2021/451’ (FINREP regulation) with a reference to ‘part 1 of the EBA IT solutions’. It is unclear what this “Part 1 of the EBA IT solutions” is referring to as it does not seem to be included on the EBA website, not under the P3 data HUB not the DPM 4.0 IT solutions. As alignment with FINREP is key and the adjustment raises a lot of unclarity, reference to ‘‘Annex V of implementing regulation 2021/451’ should be reintroduced. 
   
• Qualitative tables – The information requested as part of the Qualitative tables (Table 1 to 3) is already disclosed as part of the CSRD Sustainability Statement, therefore it is a duplicate for companies in the scope of the CSRD. In light of the Omnibus simplification efforts, we recommend EBA to assess solutions to avoid requesting duplicate information. Consultation paper discusses ‘Prevent duplication of disclosure requirements already established under other applicable Union legislation’ in paragraph 32 and 33. In this context, possibility in the ESRS is touched upon for incorporation by reference for items covered in the Pillar III reports. However please note that this is only possible if the information incorporated by reference is subject to the same level of assurance which is not the case for Pillar III disclosures. . Therefore, this is not practically possible, considering there is no assurance requirement on Pillar III disclosures. This nuance should be taken into account when avoiding duplication of disclosures. 

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