- Question ID
-
2025_7633
- 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
- Type of submitter
-
Credit institution
- Subject matter
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Template 2 - EBA validation rules v89325_m and v89326_m
- Question
-
The formula linked to the following rule IDs: v89325_m and v89326_m appears to be incorrect
- Background on the question
-
These rules imply that the amounts reported in row 0010 “Total EU area” and row 0060 “Total non-EU area” should be greater than or equal to the sum of rows 0020, 0030, 0040, 0050 and 0070, 0080, 0090, 0100 respectively, across the specified columns. However, according to the template instructions, row 0050 and 0100 represent “Of which Level of energy efficiency (EP score in kWh/m² of collateral) estimated”, which is an additional breakdown for the extent to which these data are estimated and not based on EPC labels, and as per our understanding are not part of the aggregation logic for rows 0020–0040 and 0070-0090 respectively. We therefore believe the validation rules should exclude row 0050 and 0100, as its inclusion appears to contradict the template’s design and instructions.
- Submission date
- Rejected publishing date
-
- Rationale for rejection
-
This question has been rejected because the matter it refers to has already been identified and will be considered for a forthcoming version of the Reporting framework / release of the respective validation rules.
- Status
-
Rejected question