With regard to exposures for template 1 and 5, should loans, debt and equity instruments to financial corporations be excluded from reporting and, if so, on what basis? Should exposures to financial corporations be included?
With regard to template 1
Column (b): Should exposures to counterparties that are excluded from the EU Paris-aligned Benchmarks be reported only for public companies?
Column (c): Please confirm that the ‘of which environmentally sustainable (CCM)’ column is only required for disclosure as of end 2023?
Column (j): For scope 3 emissions of counterparties: Should the PCAF and EU benchmarking sector-specific “Scope 3 phased in approach” be adopted, where only scope 3 emissions for coal, oil gas etc. be reported (from end 2020 onwards), etc.” (see here below from the EU Benchmarking directive)?
With regard to template 2, columns (h) to (n), which database should be used for buildings with EPC Labels?
With regard to template 4
Point 21: would it be acceptable for reporting institutions to use various data providers?
Is “carbon intensity” meant to include scope 3 emissions or solely scope 1 and 2? If scope 3 emissions are included, should only reported data be included or include estimated data?
Should disclosures refer only to CO2 or to all greenhouse gases in CO2 equivalent?
Is this a footprint (i.e., absolute emission) or intensity (e.g., relative based on turnover, production or the like) metric? If intensity, what is the denominator?
At what cadence should the list of companies be updated?
Are the ‘Top 20 Carbon-Intensive Firms’ with respect to a world-wide comparison?
Column (a): Does ‘Gross carrying amount (aggregate)’ require banks to report the total gross carrying amount of their banking book and part (b) ‘Gross carrying amount towards the counterparties compared to total gross carrying amount (aggregate)’ require the reporting of the ratio of the carrying amount towards the top 20 emitting companies to the total gross carrying amount?
Column (c): is the ‘of which environmentally sustainable (CCM)’ column only required for disclosure as of end 2023?
Column (d): is the ‘weighted average maturity’ only required for the carrying amount for counterparties among the top 20 carbon emitting companies?
With regard to template 5
General: What point in time and what climate change scenario should the exposure be assessed?
Point 24: 'Should reporting institutions report separately for different geographic regions, i.e., a separate excel sheet per geographic region and, if yes, what would be the appropriate level of detail for such regions?
Does the 'breakdown by geography of location' imply that the exposure should be assessed at the location level and overall aggregated exposure across all regions be reported?
Point 25: are third party data providers’ hazard models for the identification of geographies prone to climate hazards?
- Legal act: Regulation (EU) No 575/2013 (CRR)
- COM Delegated or Implementing Acts/RTS/ITS/GLs: Regulation (EU) 2022/2453 - ITS on ESG disclosures
