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.
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).