- Question ID
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2024_7225
- 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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Template 1
- Type of submitter
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Other
- Subject matter
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ESG P3 - Template 1 - Reporting of column k (GHG emissions (column i): gross carrying amount percentage of the portfolio derived from company-specific reporting)
- Question
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In Template 1, “column k (GHG emissions (column i): gross carrying amount percentage of the portfolio derived from company-specific reporting)”, should the denominator used in the calculation of the percentage be:
- the gross carrying amount of exposures which GHG emissions are available or estimated OR
- the gross carrying amount of all the exposures within the banking book portfolio regardless of whether the GHG emissions are available, estimated or not available (missing).
- Background on the question
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According to the ITS, Template 1 reports exposures towards non-financial corporates, including loans and advances, debt securities and equity instruments, classified in the accounting portfolios in the banking book excluding financial assts held for trading or held for sale assets.
The instructions given for the “column k (GHG emissions (column i): gross carrying amount percentage of the portfolio derived from company-specific reporting)” of Template 1 is that:
“Institutions shall indicate the percentage of the portfolio (gross carrying amount of the exposures) for which they have been able to estimate their counterparties’ scope 1, 2 and 3 emissions associated with institutions’ lending and investment activities based on information disclosed by their counterparties or reported to the institution on bilateral basis”
For exposures to counterparties without scope 1, 2 and 3 emissions data (no reported amount, neither estimation / missing), these exposures will not have data reported in “column i (GHG financed emissions (scope 1, scope 2 and scope 3 emissions of the counterparty) (in tons of CO2 equivalent)”.
So, for the calculation of column k, can you please clarify whether the gross carrying amount of these exposures should to be included in the denominator for the calculation of percentage (as they are still part of the Banking Book portfolio) or to be excluded?
Example: assuming both of these 2 exposures are part of the portfolio of Banking Book in scope for Template 1 reporting:
Exposure Gross Carrying Amount GHG emissions reported or estimated Exposure 1 100 Yes Exposure 2 200 No The denominator i.e. gross carrying amount used in the calculation of the percentage for column k will be based on 100 or 300?
- Submission date
- Status
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Question under review
- Answer prepared by
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Answer prepared by the EBA.