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?
No comments
2. Do you have any comments on the simplified set of information for Other listed institutions and Large subsidiaries?
Is it also possible for large subsidiaries to disclose the non-simplified templates instead of the simplified ones or is it mandatory to report the simplified templates? We need to deliver the non-simplified templates to our parent institution for consolidation. Therefore, in cases it will be easier for us to report the non-simplified version of the templates and also create the simplified templates may actually be more work and more time consuming since we would need to create both version of the templates. In the EBA public hearing the answer to the question was that this will be possible. We would like that in the future ITS a possibility to choose between the non-simplified and simplified templates for disclosure is include in written form. Please also consider that such a possibility to choose the templates must than also be implemented in the Pillar 3 data hub.
3. Do you have any comments on the simplified set of information proposed for SNCI and other non-listed institutions?
No since it’s not applicable for our institute.
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?
We welcome the proposed frequency changes. The changes will significantly reduce our workload.
5. Do you have any comments on the transitional provisions and on the overall content of section 3.5 of the consultation paper?
Please consider for the future to directly include a non-action letter from the competent authorities if you propose such an interim guidance. The way the interim guidance was published only introduced uncertainty regarding the disclosure requirements for the 30th of June 2025. Due to those uncertainties we still needed to invest time and money to be prepared to report the ESG disclosure if necessary. Also due to the timing we already prepared for our first ESG disclosure as an institute which wouldn’t have been necessary. It will also be only in parts useful for the future since the templates will already be changed when we need to report the ESG disclosure for the first time.
6. Do you have any comments on the proposed amendments to Table 1 and Table 3?
No further comment
7. Do you have any further suggestions on Table 1A?
No since it’s not applicable for our institute.
8. Do you have any comments on the proposed additions and deletions to the sector breakdown?
We don’t have further comments on the new sector breakdown. We still see the usage of NACE 2.1 problematic. Please refer therefor to question 9.
9. Do you have any views with regards to the update of the templates to NACE 2.1?
We see the update on the NACE 2.1 code problematically. The ESG disclosure would be the first reporting to adapt the NACE 2.1 codes. Since the ESG disclosure is based on FINREP we do cross references and comparisons between the reporting. Since FINREP to my knowledge isn’t updating to NACE 2.1 those comparisons wouldn’t be possible anymore. We also see the reporting of the GHG emissions problematic regarding NACE 2.1. We asked PCAF a while ago if they plan to update their database with the emission factors to NACE 2.1. At that time, they didn’t plan it. So, we would calculate GHG emissions based on NACE 2 but then report them in template 1 on NACE 2.1 and therefore create inconsistencies.
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?
In our opinion NACE code K – Telecommunication, computer programming, consulting, computing infrastructure and other information service activities should be allocated under the section Exposures towards sectors that highly contribute to climate change. In the last years the energy demand especially for technologies like AI increased and is only going to increase further. Therefore, the impact on climate change of those technologies should also be made transparent in the template.
11. Do you have any comments on the inclusion of row “Coverage of portfolio with use of proxies (according to PCAF)”?
We don’t have any comment.
12. Do you have any further comments on Template 1?
We don’t have further comments on Template 1.
13. Do you have any comments or alternative suggestions for SNCIs and other institutions that are not listed, regarding the sector breakdown?
We don’t have any comments since it’s not applicable for our institute.
14. Do you have any additional suggestions how to adjust Template 1A for SNCIs and other institutions that are not listed?
We don’t have any comments since it’s not applicable for our institute.
15. Do you have any further comments on Template 1A?
We don’t have any comments since it’s not applicable for our institute.
16. Should Template 2 in addition include separate information on EPC labels estimated and about the share of EPC labels that can be estimated?
We would welcome if Template 2 of the ESG disclosure regarding the handling of EPC and EP score estimates would get aligned with STE template 2. In the STE template information for the estimates are include for EPC labels and the EP score. So far, the ESG disclosure only allowed estimates for the EP score. Since both templates are different in that regard, we need to derive both templates separately. An alignment would make our process more streamlined.
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?
Yes, they still shall include estimates. If no estimates are included in template 2 the representation of the used data of the institutions isn’t accurate since institutes do use estimates. From our point of view no change in the disclosures is necessary.
18. Do you have any comments on the inclusion of information on covered bonds?
It is the purpose of Article 14 of the Covered Bonds Directive to provide transparency regarding the covered bonds programs of banks issuing covered bonds by disclosing sufficiently detailed information to allow investors of covered bonds to assess the profile and risks of those programs.
This objective is achieved through the publication of detailed information on the pools of loans underlying covered bonds set out in paragraph 2 of Article 14 of the Covered Bonds Directive, which currently already contains the information on market risk, credit risk and liquidity risk. In order to ensure a consistent and clear overview of all risks relevant to investor decisions regarding the cover pools of the covered bond programs on a quarterly basis, information on ESG risks in the cover pool should be required via an extension of the disclosure framework for covered bonds.
In our opinion, the amendment of template 2 of the Pillar 3 framework by the proposed row called “of which: part of a cover pool of covered bonds” would not be useful to provide the information expected from investors in covered bonds.
19. Do you have any comments on the breakdown included in columns b to g on the levels of energy performance?
We don’t have any comments. The breakdowns are working fine for us.
20. Do you have any further comments on Template 2?
We don’t have further comments.
21. Do you have any comments on Template 3?
We don’t have any comments on Template 3.
22. Do you have any comments with the proposals on Template 4 and the instructions?
We don’t have any comments on Template 4.
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?
We don’t think that the template will be improved by more granular information.
24. Do you have any further comments on Template 4?
We don’t have any further 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?
We would prefer if both version of template 5 use the same NUTS level for the breakdown. Since we are a large subsidiary under the proposed templates, we would need to report the template on NUTS level 2. At the same time we deliver our data to our parent institute for consolidation. Since they need to report on NUTS level 3 we would also need to prepare the data on NUTS level 3. This would be a higher and unnecessary extra workload. Therefore, we would prefer a general usage of NUTS level 2 for all kind of institutes. In our opinion the NUTS level 3 is to granular.
We would also like say that under the current proposal the workload increases significantly. Compared to the instructions under the current regulation we would need to create 12 templates for our parent institute and further 7 templates for our own disclosure. That would be 19 templates in total. Under the current regulation we only need to derive 1 template for our parent institute and further 1 template for our own disclosure which are 2 in total.
26. Do you have any comments on the instructions for the accompanying narrative and on whether they are comprehensive and clear?
The instructions in paragraphs 5 and 6 of the Annex XL, listing all aspects of the narrative disclosure requirements are comprehensive enough to clearly define the regulatory expectations for the narrative explanations accompanying template 5.
However, the extensive information including rationale and justifications that have to be disclosed leads to high additional effort compared to the narrative accompanying the current template 5. In our opinion, more principle-based instructions would be sufficient.
27. Do you have any further comments on Template 5 and on its simplified version Template 5A?
Same comment as under number 2. Would it also be possible for a large subsidiary to report template 5 instead of version 5A? Since we deliver data to our parent institution, we need to derive template 5. As a large subsidiary we would need to report 5A. Even though 5A is simpler than template 5 it would be a more time consuming to do both versions of the templates. We would need to maintain two different processes for the creation of the template instead of just changing the relevant values in the derivation of template 5. Also the workload would increase significantly since we would need to derive 19 templates (12 for our parent institute and 7 for our own disclosure) in total. Even though we understand the aim of the simplified version of template 5A in our case it just leads to a disproportionate workload.
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 welcome the proposal to fully align template 7 and 8 with the taxonomy delegated act. Otherwise, we would have multiple different GARs in the future (ESG disclosure and taxonomy reporting) which isn’t the idea of the GAR.
We also advice that the EBA takes into consideration if in this case it’s more feasible to completely leave out the Templates 7 & 8 in the ESG disclosure and only include a direct cross reference to the templates of the article 8 of EU-Taxonomy regulation.
29. Do you have any comments on the proposal related the BTAR and to keep it voluntary?
We welcome that the BTAR templates remains voluntary.
Can a large subsidiary also disclose the BTAR template on a voluntary basis if they want to? In our case we have the special constellation that we want to disclose the BTAR template in our own disclosure but our parent institution doesn’t. So far there is no statement in the draft if an institute which falls under the simplified approach can also report more templates or templates from the non-simplified approach on a voluntary basis.
In the EBA public hearing we already posted that question. There we got the answer that it’s possible to disclose more templates as required on a voluntary basis. We would also like advice the EBA that they take a possible voluntary disclosure in consideration for the Pillar III data hub. So that if an institute voluntarily discloses a template, it can also be included in the delivery for the Pillar III data hub.
30. Do you have any comments regarding the adjustments to template 10?
We oppose the granular differentiation of the proposed disclosures by individual environmental objectives. This is because the existing tools used by banks to assess sustainable investments which do not fulfil the EU taxonomy criteria, typically do not provide results that allow a clear allocation of the financial assets to distinct environmental objectives. In this respect, it is not possible to provide the amounts for the individual columns of template 10 without undue effort.
Therefore, we propose not to differentiate between environmental objectives, i.e. to merge the columns b to g in template 10 of the draft ITS to one column.
31. Do you have any further comments on the Consultation Paper Pillar 3 disclosures requirements on ESG risk?
We don’t 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.
We don't have any comments.
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?
We don't have any comments.
34. Are the amended template EU CR 10.5 and the related instructions clear to the respondents? If no, please motivate your response.
We don't have any comments.
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?
We don't have any comments.
36. Do the respondents consider that the “mapping tool” appropriately reflects the mapping of the quantitative disclosure templates with supervisory reporting templates?
We don't have any comments.