- Question ID
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2023_6809
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Transparency and Pillar 3
- Article
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449a
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Regulation (EU) 2022/2453 - ITS on ESG disclosures
- Article/Paragraph
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Annex I - Template 7
- Type of submitter
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Credit institution
- Subject matter
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Pillar 3 ESG Template 7 - Trading book
- Question
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Should the Trading book be considered in the “Other assets excluded from the numerator for GAR calculation (covered in the denominator)”, as positioned under the EU Taxonomy template 1?
Or should it be left in the “Other assets excluded from both the numerator and denominator for GAR calculation” category as in Pillar 3 ESG Template 7, leading to an inconsistency of reporting between the two templates?
- Background on the question
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We believe there is a mismatch between the EU Taxonomy templates and the Pillar 3 ESG disclosure ones regarding the treatment and placement of the Trading book.
The positioning of the line item Trading book differs between Pillar 3 ESG Template 7 and EU Taxonomy Template 1. In Pillar 3 ESG Template 7 the, Trading book is included in the “Other assets excluded from both the numerator and denominator for GAR calculation” (row 48), while in the EU Taxonomy template 1 the Trading book is included in the “Other assets excluded from the numerator for GAR calculation (covered in the denominator)” (row 43). This will lead to inconsistent reporting.
- Submission date
- Rejected publishing date
-
- Rationale for rejection
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This question has been rejected because the issue it deals with is already explained in the regulatory framework. In particular, please see that template 1 Assets for the calculation of GAR of Annex VI of Regulation (EU) 2021/2178, which includes Trading book under “Other assets excluded from the numerator for GAR calculation (covered in the denominator)”, while it is under “Other assets not covered for GAR calculation” and template 7 Mitigating actions: Assets for the calculation of GAR of Annex I of Regulation (EU) 2022/2453, which is in line with template 1 Assets for the calculation of GAR.
For further information on the purpose of this tool and on how to submit questions, please see “Additional background and guidance for asking questions”.
- Status
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Rejected question