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

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

We have noted that under article 433a (paragraph 2) of CRR 3, large non-listed institutions are expected to publish ESG disclosures annually. Yet, in the EBA consultation, a semi-annual frequency is proposed for these institutions, which represents a tightening of the framework.

We believe that the frequency for large non-listed institutions should be revised back to annual to ensure consistency with CRR 3. It seems essential to remain aligned with CRR 3 to avoid unnecessary complexity and reporting burden for these institutions.

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

The simplified set of information defined by the consultation paper does not necessarily mean simplification for subsidiaries. For the template 5, subsidiaries already provide information through their contribution to the consolidated reporting of the parent company. Consequently, disclosing a new template 5A for these entities is an additional requirement with the implementation of a new template which a different granularity level (NUTS 3 vs. NUTS 2). We propose to consider the simplified set of information as a regulatory minimum, and it should be possible to disclose either the same template as their parent company (template 5A for instance) or the simplified template (template 5 for instance) at the entity's discretion. It is also the same for template 1A as our other non-listed regional banks will contribute to our group consolidated reporting with templates 1 and 5 and will also have to disclose template 1A.

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

Same answer as above, we propose to consider the simplified set of information as a regulatory minimum, and it should be possible to disclose for entities either the same template as their parent company or the simplified template at the entity's discretion.

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 proposed approach is coherent and relevant as:

template 3 is based on NZBA targets that we disclose on an annual basis;
templates 6 to 10 are based on the taxonomy reporting that is annual (disclosed in the sustainability reporting).

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

We appreciate the inclusion of transitional provisions to adapt to the revised ESG disclosure requirements.

We are grateful for the EBA's confirmation during their hearing that institutions may begin applying the transitional provisions right away, without needing to wait for the forthcoming no-action letter that the EBA will still provide.

However, we wish to highlight two specific areas of concern:

Firstly, regarding columns: Since EU Taxonomy alignment data is required within Templates 1 and 4 (in the column labeled 'of which environmentally sustainable CCM'), we formally request that the EBA confirm these specific data fields/columns fall within the scope of the established transitional arrangements.
Secondly, concerning XBRL: We seek confirmation that ESG-related ad hoc XBRL reporting for templates 6-10 will not be mandatory until at least the first quarter of 2027. In general, all digital frameworks should be coherent and updated with the templates requested during the transitional period.

Additionally, we would like to request an 18-month delay from the publication of the Implementing Technical Standards (ITS) to implement the changes in template 5 of the disclosure requirements, as they are challenging especially the distinction between the type of risks.

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

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

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

See answer to question 10 concerning NACE codes K and L.

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

We support the implementation of the revised NACE codes and do not foresee significant operational challenges for our organization with this transition, with one important exception regarding the reporting date of June 30, 2026.

We note a potential timing inconsistency in the implementation schedule: while the European Banking Authority (EBA) and European Central Bank (ECB), following the Joint Bank Reporting Committee (JBRC) advice, recommend implementing the revised classification from January 1st 2026, the new Pillar 3 ESG templates are only scheduled to be used from the reference date of December 31st 2026.

This creates a six-month period where institutions would need to maintain dual reporting systems. We therefore request alignment of these implementation dates to ensure a more streamlined transition and avoid unnecessary operational complexity.

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?

Given the increasing reliance on artificial intelligence, cloud computing, and digital infrastructure services, this sector exhibits a growing potential to produce significant carbon emissions. Therefore, we advocate for placing NACE K-63 under the category "Exposures towards sectors that highly contribute to climate change."

More broadly, we support eliminating the "other sectors" classification entirely, maintaining that economic sectors either contribute meaningfully to climate change or they do not. Establishing a middle-ground category between these two would lack relevance and create confusion for data users.

Consequently, we believe sector L – Financial and insurance activities should also be assigned to one of these two definitive categories rather than remaining in an ambiguous classification.

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

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

For large institutions, we request that the column (c) related to exposure alignment be published annually rather than semi-annually, as it is directly linked to taxonomy reporting which operates on an annual cycle. This adjustment would ensure consistency between related reporting requirements and reduce unnecessary interim reporting burdens.

It is also important to gray this column for entities that are not subject to the Taxonomy Regulation.

Additionally, line 56 “total” requires credit institutions to disclose their total exposure: scopes 1, 2 and 3 for all sectors. This line also includes the total scopes 1, 2 and 3 of lines 53 to 55 “Exposures towards sectors other than those that highly contribute to climate change” for which credit institutions shall not disclose scope 1, 2 and 3. Can you clarify that the total expected in line 56 does not include these lines 53 to 55?

To enhance clarity, we also recommend darkening lines 1 “Exposures towards sectors that highly contribute to climate change” and 52: “Exposures towards sectors other than those that highly contribute to climate change” as we understand that no information should be reported.

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

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

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

We believe that the methodology applied to physical risks should be clarified in general (see additional details in response 27), as without this specification, there will be no comparability between institutions. Once this issue of methodological divergences is resolved, we consider that the same level of granularity should be applied to all templates concerning physical risk (templates 1A, 5, and 5A).

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

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?

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

The regulatory requirements for covered bond disclosures are already managed through the EU Covered Bond Directive (Directive 2019/2162). To prevent scattered reporting and misaligned disclosure schedules, we believe that ESG-related data should be integrated within the specialized covered bond reporting frameworks.

We believe it is not necessary to include information on covered bonds in the template 2.

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

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

We understand that institutions should report information related to the total gross carrying amount in lines G1 (Of which level of energy performance (EP score in kWh/m² of collateral) estimated), G2 (Without EP score in kWh/m² of collateral (neither measured nor estimated) and O (Without EPC label of collateral). Given the information expected, we believe that it would be clearer if the information was required in percentage estimated (ex: % of EP score in kWh/m² of collateral).

21. Do you have any comments on Template 3?

Regarding Template 3, we strongly emphasize the need for a clearly defined methodology to determine whether a sector is considered significant for our institution. Without explicit criteria and standardized approaches for this assessment, there will be no comparability between institutions, as each entity may apply different thresholds, metrics, or evaluation frameworks. This lack of methodological consistency would undermine the purpose of harmonized ESG reporting and compromise the ability of supervisors and stakeholders to conduct meaningful cross-institutional analysis and benchmarking exercises.

Furthermore, the EBA should clarify the relationship with TCFD sub-sectors, as we believe that, de facto, all sectors are analyzed through the lens of materiality, including the 18 TCFD sub-sectors. Therefore, we do not understand why these sub-sectors are specifically mentioned and what their particular treatment should be compared to any other sector or sub-sector. This ambiguity requires urgent clarification to ensure consistent implementation across institutions.

Finally, IAE sectors concern only energy sectors while template 3 concerns all sectors.

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

We note that within the revised framework:

Template 1 now includes a more granular breakdown of exposures to fossil fuel-related sectors.
Template 4 specifically targets exposures to the 20 highest-emitting companies globally.

We would like to highlight a concern regarding potential redundancy between these two templates. The information requested in Table 4 appears to significantly overlap with the fossil fuel sector exposures already captured in Table 1, as the world's highest-emitting companies are predominantly active in fossil fuel-related sectors.

This duplication creates an unnecessary reporting burden without providing proportionate additional insight. We recommend that the EBA either:

Clarify the distinct analytical purpose of each table and ensure they complement rather than duplicate each other or consider consolidating these reporting requirements to eliminate redundancy while maintaining the desired level of disclosure.

Additionally, we request that the column related to exposure alignment be published annually rather than semi-annually, as it is directly linked to taxonomy reporting which operates on an annual cycle. This adjustment would ensure consistency between related reporting requirements and reduce unnecessary interim reporting burdens.

It is also important to gray this column for entities that are not subject to the Taxonomy Regulation.

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, we are not in favor of more granular information.

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

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?

While we do not question the desire to move towards greater geographical precision, we believe that this increased granularity will not necessarily improve the quality of the information. In addition, the publication of 12 templates is not in line with the desire to simplify the reporting of Pillar 3. We therefore suggest limiting the number of template 5 to 3: total exposures, European Union, Top 10 NUTS 3 aggregated. Indeed, methodological practices vary greatly from one institution to another, particularly in the definition of sensitivity to physical risks (not harmonized), the time horizons considered (some going as far as 2050, others remaining short-term), or the climate scenarios chosen (some institutions using extreme scenarios, others relying on RCP 4.5). As long as these methodological differences persist, the additional level of geographical detail will not create greater clarity and comparability. Furthermore, work carried out within the European Banking Federation (EBF) has already highlighted both common challenges between institutions and significant heterogeneity in methodological approaches, thus highlighting the need for greater clarification from the EBA on physical risk reporting requirements.

Generally speaking, with new information to be disclosed and a more detailed geographical dimension, these various developments do not simplify this table and do not contribute to comparability between institutions.

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

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

Several operational points require clarification from the EBA in our view to ensure consistent implementation of the table. First, an important question concerns the location of exposures in the case of a group with multiple sites: how to determine the reference geographical area for the exposure? It would be essential for the EBA to clarify this point.

Furthermore, the distribution of exposures across several risks also needs to be clarified: if the same exposure is simultaneously affected by several physical risks (for example, both water and land), should it appear in several columns? And if so, should it be counted only once in the total? This question is crucial to avoid double counting and ensure the intelligibility of the data. This type of situation had already been raised in the context of the old table relating to acute and chronic risks, and it would be useful for the EBA to refer to the existing FAQ (2024-7080) on this point or publish new methodological guidance.

Furthermore, Columns l to p, which focus on stage 2 exposures, impairments, and non-performing exposures, do not provide relevant information on physical risks. The risk measured in these columns is comprehensive and encompasses all risk types, having only an indirect connection to physical risks. Therefore, these columns do not contribute meaningful insights specific to physical risk assessment. In line with the simplification objective, we propose removing these columns as they add complexity without delivering physical risk-specific value.

Finally, we wonder why keeping the mention of “acute” and “chronic” in the cell “Z-axis - Geographical area subject to climate change physical risk acute and chronic events”.

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?

We understand that templates 6 to 10, on the GAR, will only be required for “large institutions subject to Article 8 of the Taxonomy Regulation”. We do not see the point for institutions to publish these indicators related to the GAR two times (one in the Pillar 3 ESG and one in the sustainability reporting) and propose to delete at least templates 7 and 8. Templates 9 on BTAR and 10 on “other climate mitigating action” could remain in the Pilar 3 as they give an information that is not disclosed in other reporting.

Consequently, we propose to disclose templates 7 and 8 in the Pillar 3 reporting on a voluntary basis when the entity would also publish template 9 on a voluntary basis.

We request that the modifications implemented in the GAR through the Omnibus package (particularly the reduction of asymmetry between numerator and denominator by excluding derivatives, cash, goodwill etc.) should also be applied to the BTAR. This alignment would ensure consistency between the two reporting frameworks and provide a more accurate representation of transition alignment.

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

We support the proposal.

Moreover, we would like EBA to amend template 9.1 (Template 9.1: Mitigating actions: Assets for the calculation of BTAR) to ensure coherence and avoid misinterpretation:

Line 12 “total BTAR assets” should be renamed “total assets in the numerator”.

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

We have 3 points regarding template 10:

There is a lack of clarity regarding which specific instruments should be included in Template 10 under the rows designated for equity exposures. Additionally, the criteria for classifying an equity exposure as a 'green exposure' remain undefined.
The ITS incorporates a new breakdown category "Of which: small and medium-sized enterprises" under loans and advances to non-financial corporations in Template 10. This breakdown is not present in either the GAR or BTAR templates. In the interest of simplification and ensuring consistency across different templates, we propose eliminating this breakdown.
We do not understand the line “Of which: Loans collateralised by residential immovable property” for non-financial undertakings.

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

32. Are the new template EU SB 1 and the related instructions clear to the respondents? If no, please motivate your response.

33. Do the respondents agree that the new template EU SB 1 and the related instructions fit the purpose and meet the requirements set out in the underlying regulation?

34. Are the amended template EU CR 10.5 and the related instructions clear to the respondents? If no, please motivate your response.

35. Do the respondents agree that the amended template EU CR 10.5 and the related instructions fit the purpose and meet the requirements set out in the underlying regulation?

36. Do the respondents consider that the “mapping tool” appropriately reflects the mapping of the quantitative disclosure templates with supervisory reporting templates?

The current DPM is not updated to reflect the changes in the templates made in the consultation. For instance, template 3 still contains the 8 mandatory sectors as rows. However, the table has been modified and no longer includes mandatory rows (now focusing on sectors relevant to the institution). We request clarification that the DPM should be modified accordingly and should no longer include mandatory sectors as it does currently.

This inconsistency between the DPM structure and the revised table format needs to be addressed to ensure proper implementation and reporting.

Name of the organization

Crédit Agricole SA