Question ID
2024_7013
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Transparency and Pillar 3
Article
449a
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2022/2453 - ITS on ESG disclosures
Article/Paragraph
Template 2 in Annex I
Type of submitter
Competent authority
Subject matter
Disclosures in case of lack of label in EPCs
Question

What shall be reported in columns h-n in case local EPCs do not present labels in the form of letters (A-G), but only level of energy efficiency? Shall these columns be left blank or “0” can be disclosed? Is it acceptable that the banks remove these columns from the template and do not disclose them at all?

In addition, what shall be reported in this case in columns o and p? Column “o” is named as “Without EPC label of collateral” and it may indicate that the values to be disclosed in this column refer to the information in columns h-n.

 
Background on the question

Lack of EPC labels in the form of letters is a current state for PL banks, therefore different practices with regard to Template 2 are observed.

Submission date
Final publishing date
Final answer

Institutions shall disclose the complete Template 2, leaving columns h-n empty in case EPC labels (A to G) are not available. This should be accompanied by the relevant explanation in the accompanying qualitative narrative. Under columns o and p of Template 2, institutions shall provide information on exposures without EPC information of collateral, as per paragraph 5 of instructions to Template 2 (Annex II of the Commission Implementing Regulation (EU) 2022/2453). This information should be further broken-down to disclose information under column p on the total gross carrying amount for which the level of energy efficiency was estimated by the institution (which would not be filled in the case at stake).

Status
Final Q&A
Answer prepared by
Answer prepared by the EBA.

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