Question ID
2025_7292
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
Not applicable
Type of submitter
Credit institution
Subject matter
Clarifications on the perimeter of templates 2 and 5 Collateralized loans portfolio
Question

The Bank would like to clarify whether the same perimeter should be applied in ESG Pillar 3 Templates 2 and 5 regarding loans collateralized by residential/commercial property in column 010 (Gross Carrying Amount). Specifically, Template 2 requires banks to disclose the energy efficiency of the collateral for loans secured by immovable property, including cases where the Energy Performance Certificate (EPC) is available or unavailable, with the percentage of estimated EPCs provided when the certificate is unavailable. Based on this guidance, it seems that Template 2 would include only assets eligible for Energy Performance Certification as per relative legislation, as EPCs cannot be defined for non-eligible assets. In contrast, Template 5 would appear to cover both EPC-eligible and non-eligible assets. It would be helpful to understand if this interpretation aligns with the intended approach and whether column 010 of Template 2 should specifically reflect the subset of loans collateralized by residential/commercial property that are eligible for EPC.

Background on the question

In EBA Q&A 2023_6714 it is specified that “the amounts reported as “loans collateralized by immovable property” in templates 2 and 5 should match the carrying amount of the loans collateralized by immovable property reported in FINREP. The Bank does not interpret the Q&A 2023_6714 as a requirement for Templates 2 and 5 to have the same perimeter, aligned with specific FINREP sub-perimeters, but as methodological guidelines for the calculation of Gross Carrying Amount. Subsequently, the Bank has followed the Q&A so that the definition of Gross Carrying Amount is aligned in Pillar 3 and FINREP Report. With the Q&A submitted here, further clarifications on the definition of the perimeter of collaterals included in both templates is requested. 

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because the matter it refers to has been answered in Q&A 6714.

The Single Rule Book Q&A tool has been established to provide explanations and non-binding interpretations on questions relating to the practical application or implementation of the provisions of legislative acts referred to in Article 1(2) of the EBA’s founding Regulation, as well as associated delegated and implementing acts, and guidelines and recommendations, adopted under these legislative acts.

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Status
Rejected question