ANNEX II
‘ANNEX XL
Instructions for disclosure of ESG risks
1.
Institutions shall disclose the information referred to in Article 449a of Regulation (EU) No 575/2013 by following the instructions provided in this Annex. The instructions are to be used to complete the tables and templates which are set out in Annex XXXIX to this Regulation.
2.
(a) | ‘environmental, social or governance (ESG) risks’ means the risk of losses arising from any negative financial impact on the institution stemming from the current or prospective impacts of environmental, social or governance (ESG) factors on the institution’s counterparties or invested assets; |
(b) | ‘environmental risk’ means the risk of losses arising from any negative financial impact on the institution stemming from the current or prospective impacts of environmental factors on the institution’s counterparties or invested assets, including factors related to the transition towards the following environmental objectives: Environmental risk includes both physical risk and transition risk. climate change mitigation; climate change adaptation; the sustainable use and protection of water and marine resources; the transition to a circular economy; pollution prevention and control; the protection and restoration of biodiversity and ecosystems; |
(c) | ‘physical risk’, as part of the overall environmental risk, means the risk of losses arising from any negative financial impact on the institution stemming from the current or prospective impacts of the physical effects of environmental factors on the institution’s counterparties or invested assets; |
(d) | ‘transition risk’, as part of the overall environmental risk, means the risk of losses arising from any negative financial impact on the institution stemming from the current or prospective impacts of the transition to an environmentally sustainable economy on the institution’s counterparties or invested assets; |
(e) | ‘social risk’ means the risk of losses arising from any negative financial impact on the institution stemming from the current or prospective impacts of social factors on the institution’s counterparties or invested assets; |
(f) | ‘governance risk’ means the risk of losses arising from any negative financial impact on the institution stemming from the current or prospective impacts of governance factors on the institution’s counterparties or invested assets. |
3.
References to the international and Union policy frameworks and available benchmarks throughout these instructions include: the Paris Agreement adopted under the United Nations Framework Convention on Climate Change (*1) (the ‘Paris Agreement’), the Communication from the Commission on the European Green Deal (*2), Directive 2013/34/EU of the European Parliament and of the Council (*3), Directive 2014/95/EU of the European Parliament and of the Council (*4), the Communication from the Commission – Guidelines on non-financial reporting: Supplement on reporting climate-related information (*5), the guidance made available by the Task Force on Climate-related Financial Disclosures (TCFD) Recommendations (*6), the United Nations Environment Programme Finance Initiative (UNEP FI) (*7), the Global Reporting Initiative Sustainability Reporting Standards (*8), and the United Nations’ Principles for Responsible Investment (UNPRI) (*9).
Table 1 – Qualitative information on Environmental risk: Free format text boxes for disclosure of qualitative information in Annex XXXIX.
4. | Institutions shall use the following instructions to complete Table 1 – ‘Qualitative information on Environmental risk’ as set out in Annex XXXIX to this Regulation to describe the integration of environmental risks, including specific information on climate change risks and on other environmental risks, in their business strategy and processes, governance and risk management. This is for the purposes of Article 449a of Regulation (EU) No 575/2013, read in conjunction with Article 435 of that Regulation.
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Table 2 – Qualitative information on Social risk: Free format text boxes for disclosure of qualitative information in Annex XXXVII
5. | Institutions shall use the following instructions to complete Table 2 – ‘Qualitative Information on Social risk’ set out in Annex XXXIX to this Regulation, in order to describe the integration of social risks in their business strategy and processes, governance and risk management, in accordance with Article 449a of Regulation (EU) No 575/2013 in conjunction with Article 435 of that Regulation.
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Table 3 – Qualitative information on Governance risk: Free format text boxes for disclosure of qualitative information in Annex XXXVII
6. | Institutions shall use the following instructions to complete Table 3 – Qualitative information on Governance risk set out in Annex XXXIX to this Regulation in order to describe the integration of governance risks in their governance and risk management, in accordance with of Article 449a of Regulation (EU) No 575/2013, read in conjunction with Article 435 of that Regulation.
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Template 1 – Banking book – Indicators of potential climate change transition risk: Credit quality of exposures by sector, emissions and residual maturity. Fixed format.
1. | Institutions shall use the following instructions to complete template 1 set out in Annex XXXIX to this Regulation to provide information on the exposures that are more prone to the risks that institutions may face from the transition to a low-carbon and climate resilient economy. For the purposes of Article 449a of Regulation (EU) No 575/2013: institutions shall disclose information on their exposures towards non-financial corporates operating in carbon-related sectors, and on the quality of those exposures, including non-performing status, stage 2 classification, and related provisions as well as maturity buckets; institutions shall start disclosing information on scope 1, 2 and 3 emissions of their counterparties, if already available, including qualitative information in the narrative accompanying this template on the methodology and sources used for the calculation of those emissions. Where institutions are not yet estimating their counterparties’ emissions associated with their financing activities, including lending and investment activities, they shall disclose information on their plans to implement methodologies to estimate and disclose this information. Institutions shall start disclosing information in columns (i) to (k) of the template with first disclosure reference date as of 30 June 2024. |
2. | Institutions shall include in the narrative accompanying the template, explanations on the information disclosed and the changes compared to previous disclosure periods, as well as any implications that those exposures may have in terms of credit, market, operational, reputational and liquidity risks for the institutions. |
3. | Institutions shall include in the rows of the template the breakdown of the gross carrying amount of loans and advances, debt securities and equity instruments to non-financial corporations, other than those held for trading, by sector of economic activities using the Nomenclature of Economic Activities (NACE) codes, laid down in Regulation (EC) No 1893/2006 of the European Parliament and of the Council (*11), based on the principal activity of the counterparty. They shall also include subtotals that aggregate the gross carrying amount of exposures towards sectors and subsectors that highly contribute to climate change. In particular, reference is made to the sectors listed in Sections A to H and Section L of Annex I to Regulation (EC) No 1893/2006, which include the oil, gas, mining and transportation sectors, as sectors that highly contribute to climate change, as specified in Recital 6 of Commission Delegated Regulation (EU) 2020/1818 (*12); and a subtotal of exposures towards “other sectors” not mentioned in that Recital. |
4. | The counterparty NACE sector allocation shall be based on the nature of the direct counterparty. Where the institutions’ counterparty is a holding company, institutions shall consider the NACE sector of the specific obligor under the holding company (if different from the holding company) which receives the funding (i.e. the specific subsidiary of the holding company in question) rather than that of the holding company, particularly in those cases where the obligor that is benefiting from the financing is a non-financial corporate. Similarly, when the direct counterparty of an institution (the obligor) is a special purpose vehicle (SPV), institutions shall disclose the relevant information under the NACE sector associated with the economic activity of the parent company of the SPV. The classification of the exposures incurred jointly by more than one obligor shall be based on the characteristics of the obligor that was the more relevant, or determinant, for the institution to grant the exposure. The distribution of jointly incurred exposures by NACE codes shall be driven by the characteristics of the more relevant or determinant obligor. Institutions shall disclose information by NACE codes with the level of granularity required in the rows of the template.
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Template 2: Banking book – Indicators of potential climate change transition risk: Loans collateralised by immovable property – Energy efficiency of the collateral. Fixed format.
1. | Institutions shall use the following instructions to disclose the information required in ‘Template 2: Banking book – Indicators of potential climate change transition risk: Loans collateralised by immovable property – Energy efficiency of the collateral’, as set out in Annex XXXIX to this Regulation. |
2. | Directive 2010/31/EU of the European Parliament and of the Council (*16) and Directive 2012/27/EU of the European Parliament and of the Council (*17) promote policies that aim to achieve a highly energy efficient and decarbonised building stock by 2050. Directive 2010/31/EU introduced the Energy performance certificates (EPC) as instruments for improving the energy performance of buildings. Those certificates are referred to as a certificate recognised by a Member State or by a legal person designated by it, which indicates the energy performance of a building or building unit, calculated in accordance with that Directive. |
3. | This template shows the gross carrying amount, as referred to in Part 1 of Annex V to Implementing Regulation (EU) 2021/451, of loans collateralised with commercial and residential immovable property and of repossessed real estate collaterals, including information on the level of energy efficiency of the collaterals measured in terms of kWh/m2 energy consumption (columns (b) to (g) of the template), in terms of the label of the energy performance certificate (EPC) of the collateral as referred to in Article 2, point (12), of Directive 2010/31/EU for Member States, or as defined in any relevant local regulation for those exposures outside the Union, where a mapping to the Union EPC label exists (columns (h) to (n)). |
4. | In particular, in columns (b) to (g), institutions shall disclose the gross carrying amount of exposures by energy efficiency buckets based on the specific energy consumption of the collateral in kWh/m2, as indicated in the EPC label of the collateral or estimated by institutions in the absence of the EPC label. Institutions shall indicate in rows 5 and 10 of the template the extent to which those data are estimated and not based on EPC labels. In columns (h) to (n), institutions shall disclose the gross carrying amount of exposures grouped by the EPC label of the collateral for those collaterals where the EPC is available to the institution. |
5. | When disclosing the EPC distribution of the collaterals, institutions shall disclose separately, in column (o), those exposures for which they do not have the EPC information of the collateral. Where institutions do not have the EPC information, but are using internal calculations to estimate the energy efficiency of the collateral, institutions are to disclose the percentage of the exposures without EPC label of the collateral for which they are providing estimates (the percentage is to be computed based on the gross carrying amount of the exposures). Institutions shall disclose the total gross carrying amounts by energy consumption level and by EPC label, with a breakdown by location (Union vs non-Union area) differentiating between loans collateralised by commercial immovable property, loans collateralised by residential immovable property and collateral obtained by taking possession. |
6. | In the case of exposures to entities located in third countries where there is no EPC label equivalent, institutions shall leave columns (h) to (n) blank. However, institutions shall disclose the information required in columns (o) and (p) and, when relevant, columns (b) to (g) with estimated data. |
7. | For those exposures linked to more than one collateral, such as two immovable properties, the energy efficiency information of the properties linked to the exposure shall be split and disclosed separately under energy efficiency levels (both for the KWh/m2 of the collateral, columns (b) to (g), and for the EPC label, columns (h) to (n) corresponding to energy efficiency of each collateral). More specifically, institutions shall calculate the share of each collateral in the gross carrying amount of exposure based on the value of the collateral and disclose under the energy efficiency bucket linked to each collateral. For example, the institution has a loan with a gross carrying amount of EUR 100 000 collateralised by two properties: property A and property B. Property A has a collateral value of EUR 80 000 and EPC label A, while property B has a collateral value of EUR 70 000 and EPC label D. In this example, institutions should disclose EUR 53 333 (that is EUR 100 000 * [80 000/(80 000 + 70 000)] under EPC label A and EUR 46 667 (that is EUR 100 000 * [70 000/(80 000 + 70 000)] under EPC label D, both corresponding to the specific loan in question. |
Template 3: Banking book – Indicators of potential climate change transition risk: Alignment metrics. Flexible format (fixed columns, flexible rows).
1. | Institutions shall use the following instructions to disclose the information required in ‘Template 3: Banking book – Indicators of potential climate change transition risk: Alignment metrics’, as set out in Annex XXXIX to this Regulation. |
2. | Institutions shall disclose in this template information on their alignment efforts with the objectives of the Paris Agreement for a selected number of sectors. The disclosures on the alignment shall capture the extent to which financial flows are consistent with a pathway towards low greenhouse gas emissions and climate-resilient development as referred to in the Paris Agreement. The economic scenario that describes that decarbonisation pathway is the International Energy Agency (IEA) Net Zero Emissions by 2050 Scenario (NZE2050) (*18). Institutions shall take into account that scenario. Given that the IEA provides scenarios at global level and some specific metrics at European level, institutions are to measure the distance from the IEA scenario benchmarks at global level and, where the specific European level metrics are available, at European level. |
3. | Institutions that are already estimating information on their sectoral alignment to the Paris Agreement shall disclose the information in this template. Institutions are to explain in the narrative part accompanying the template the method used and the data source. Those institutions that are not yet estimating their sectoral alignment shall disclose information on their plans to implement a method to estimate and disclose that information. In any case, institutions shall start disclosing the information included in this template with first disclosure reference date as of 30 June 2024. |
4. | Institutions shall disclose in this template: Columns (a) and (b): these columns contain the sectors (IEA sectors) in column (a) under which rows 1-8 list the mandatory minimum set of sectors, and subsectors (NACE sectors in column (b) according to the minimum ‘list of NACE sectors to be considered’ as indicated in the template). Where the institution’s counterparty is a holding company, institutions shall consider the NACE sector of the specific obligor controlled by the holding company (if different from the holding company) which receives the funding rather than that of the holding company, particularly in those cases where the obligor is a non-financial corporate. Similarly, where the direct counterparty of the institution (the obligor) is a special purpose vehicle (‘SPV’), institutions shall disclose the relevant information under the NACE sector associated with the economic activity of the parent company of the SPV. The classification of the exposures incurred jointly by more than one obligor shall be based on the characteristics of the obligor that was the more relevant, or determinant, for the institution to grant the exposure. Institutions shall disclose information by NACE codes with the level of granularity required in column (b). Column (c): the gross carrying amount as defined in Part 1 of Annex V to Implementing Regulation (EU) 2021/451 of those exposures towards non-financial corporates in each of the sectors specified in columns (a) and (b), including loans and advances, debt securities and equity instruments, classified in the accounting portfolios in the banking book in accordance with that Implementing Regulation, excluding financial assets held for trading or held for sale assets. Columns (d) and (e): alignment metric(s) applied by the institution and closest year of reference for the alignment metric(s) for each sector. Institutions shall use the alignment metric(s) that can be measured against the Net Zero Emissions by 2050 Scenario (NZE2050). Institutions are to ensure that the metrics allow to comprehensively disclose the institutions’ financed production capacities and encompass all relevant carbon-intensive financed activities. Some sample metrics are included in the template. Institutions are to disclose several metrics for each sector that is relevant to their financing activity. These are to cover emission intensity metrics, technology mix-based metrics and production-based metrics. Institutions are to rely on the assessment of the underlying assets and activities linked to the financial instruments. For loans whose use of proceeds is known, the value shall be included for the relevant sector and alignment metric. For loans whose use of proceeds is unknown, the gross carrying amount of the exposure shall be allocated to the relevant sectors and alignment metrics based on the counterparties’ activity distribution, including by counterparties’ turnover by activity. Institutions shall add a row in the template for each relevant combination of sectors disclosed in column (b) and alignment metrics included in column (d). Column (f): the point in time distance of the column (d) metric(s) to the 2030 data points of the Net Zero Emissions by 2050 Scenario (NZE2050), shall be expressed in percentage points. That distance shall represent the current degree of alignment with the scenario indicator for 2030 and shall be expressed as the difference between the indicator in column (d) and the IEA scenario projection for 2030, divided by the scenario benchmark indicator and converted into percentage terms. Institutions can find the relevant information and the applicable scenario indicators for 2030 per sector on the IEA website. In particular, institutions shall refer to the “Net Zero by 2050 – A Roadmap for the Global Energy Sector” that the IEA publish on an annual basis (*19). The specific data points and indicators can be downloaded from the excel table included in the Net Zero by 2050 Scenario designed by the International Energy Agency The exposures’ underlying activities shall be considered aligned where the level of the indicator is below that of the benchmark for decreasing benchmarks (carbon intensive activities) or above for increasing benchmarks (low carbon activities); \mathrm{Distance} = \frac{\mathrm{Metric\ at\ reference\ year} - (\mathrm{IEA\ scenario\ metric\ in\ 2030)}}{\mathrm{(IEA\ scenario\ metric\ in\ 2030)}}*100 Column (g): institutions’ target for 3 years after the year of reference indicated in column (e) and the alignment metric indicated in column (d). Column (g) shall indicate the portfolio alignment path and targets that institutions plan to achieve to remain on track with the IEA scenario in the long term. |
Template 4 – Banking book – Indicators of potential climate change transition risk: Exposures to top 20 carbon-intensive firms. Fixed format
1. | Institutions shall use the following instructions to disclose the information required in ‘Template 4: Banking book – Indicators of potential climate change transition risk: Exposures to top 20 carbon-intensive firms, as set out in Annex XXXIX to this Regulation. |
2. | Institutions shall disclose in this template aggregate information on exposures towards the most carbon-intensive counterparties in the world. They shall include aggregated and anonymised information on the gross carrying amount of exposures towards up to 20 counterparties that are among the top 20 most carbon-intensive corporates worldwide. Information shall be based on publicly available reputable and accurate information. Examples of data sources to identify the top carbon-intensive companies include the Carbon Majors Database and Reports of the Carbon Disclosure Project and Climate Accountability Institute as well as Thomson Reuters. |
3. | Institutions shall disclose in the narrative accompanying the disclosure the source of the data they use. Where institutions are not able to identify exposures towards the top 20 carbon-intensive firms in the world, they shall explain why they have not indicated such exposures, including in the case in which they do not have any exposures towards the top 20 carbon-intensive firms in the world.
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Template 5 – Banking book – Indicators of potential climate change physical risk: Exposures subject to physical risk. Fixed format.
1. | Institutions shall use the following instructions to disclose the information required in ‘Template 5: Banking book – Indicators of potential climate change physical risk: Exposures subject to physical risk’, as set out in Annex XXXIX to this Regulation. |
2. | Institutions shall include in this template information on exposures in the banking book, including loans and advances, debt securities and equity instruments not held-for-trading and not held-for-sale, towards non-financial corporates, on loans collateralized with immovable property and on repossessed real estate collaterals, exposed to chronic and acute climate-related hazards, with a breakdown by sector of economic activity (NACE classification) and by geography of location of the activity of the counterparty or of the collateral, for those sectors and geographical areas subject to climate change acute and chronic events. |
3. | For the identification of geographies prone to specific climate-related hazards, institutions shall use dedicated portals and databases. To obtain information on the characteristics of locations sensitive to climate-change events, institutions may use the data offered by Union bodies and by national government authorities including meteorological, environmental, statistical agencies or geoscience organisations. Examples of data sources to identify geographical areas subject to climate change related hazards include (*20): GFDRR – ThinkHazard! (covering heatwaves, water scarcity and stress, floods, wildfires, hurricanes, landslide); PREP – PREPdata (coastal flood, extreme heat, landslide, water scarcity and stress, wildfire); WRI – Aqueduct Water Risk Atlas (flood, coastal flood, water scarcity and stress) Swiss Re – CatNet® (flood, tropical cyclone (hurricane &typhoon), wildfire); World Bank – Climate Change Knowledge Portal (extreme heat, extreme precipitation, drought); PCA – Global Drought Risk platform (drought); NOAA – Historical hurricane tracks (tropical cyclone (hurricane &typhoon). |
4. | When the counterparty is a holding company, institutions shall consider the NACE sector of the specific obligor controlled by the holding company (if different than the holding company itself) which receives the funding, particularly in those cases where the obligor is a non-financial corporate. Similarly, where the direct counterparty of the institution (the obligor) is an SPV, institutions shall disclose the relevant information under the NACE sector associated with the economic activity of the parent company of the SPV. The classification of the joint exposures towards more than one obligor shall be based on the characteristics of the obligor that was the most relevant for the institution to grant the exposure. The distribution of jointly incurred exposures by NACE codes shall be driven by the characteristics of the more relevant or determinant obligor. |
5. | Institutions shall disclose the information in this template on a best effort basis and explain in the narrative accompanying the template the sources of information and methods that they have used to identify exposures subject to climate-change physical risk.
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Template 6 – Summary of key performance indicators (KPIs) on the Taxonomy-aligned exposures. Fixed format.
1. | Institutions shall provide in template 6 an overview of the KPIs calculated on the basis of templates 7 and 8 of Annex XXXIX, including the green asset ratio (GAR) as referred to in Commission Delegated Regulation (EU) 2021/2178 (*21) |
2. | While Delegated Regulation (EU) 2021/2178 requires entities to estimate and disclose the GAR twice, once based on the turnover taxonomy alignment of the counterparty (for non-financial corporates) for those exposures the purpose of which is not to finance specific identified activities (general purpose lending), and again based on the capital expenditure (CapEx) taxonomy alignment of the counterparty for the same general purpose lending exposures, in this template institutions shall only disclose the GAR once, based on the turnover alignment of the counterparty for the general purpose lending part only. |
3. | For the stock, GAR (climate change mitigation), GAR (climate change adaptation), GAR (climate change mitigation and climate change adaptation) shall correspond to the KPI included in columns (b), (g) and (l) respectively of Template 8, accordingly. Similarly, for the flow, GAR (climate change mitigation), GAR (climate change adaptation), GAR (climate change mitigation and climate change adaptation) shall correspond to the KPI included in row 1, columns (r), (w) and (ab) of the same Template 8. |
4. | Information on the coverage shall be included in Template 8, row 1, column (p) for GAR stock, and (af) for GAR flow. |
5. | Institutions shall disclose this information with first reference date as of 31 December 2023, which is in line with the first reference date for the disclosure of the information on the GAR referred to in Delegated Regulation (EU) 2021/2178. |
Template 7 – Mitigating actions: Assets for the calculation of GAR. Fixed format
1. | Institutions shall use the following instructions to disclose the information required in ‘Template 7 – Mitigating actions: Assets for the calculation of GAR’, as set out in Annex XXXIX to this Regulation. |
2. | Institutions shall disclose in this template information on gross carrying amount of institutions’ loans and advances, debt securities and equity instruments on their banking book, with a breakdown of the information by type of counterparty, including financial corporations, non-financial corporations, households, local governments as well as real estate lending towards households, and the taxonomy eligibility and taxonomy alignment of the exposures with regard to the environmental objectives of climate change mitigation and climate change adaptation as referred to in Article 9, points (a) and (b), of Regulation (EU) 2020/852. |
3. | In particular, institutions shall include in this template information necessary for the calculation of the GAR in accordance with Delegated Regulation (EU) 2021/2178. While Delegated Regulation (EU) 2021/2178 requires institutions to estimate and disclose the GAR twice, once based on the turnover taxonomy alignment of the counterparty (for non-financial corporates) for those exposures the purpose of which is not to finance specific identified activities (general purpose lending), and again based on the CapEx taxonomy alignment of the counterparty for the same general purpose lending exposures, in this template institutions shall only disclose the GAR once based only on the turnover alignment of the counterparty for the general purpose lending part. |
4. | Based on that information, institutions shall calculate and disclose their GAR as referred to in Delegated Regulation (EU) 2021/2178. The information included shall relate to climate change mitigation and climate change adaptation as referred to in Article 9, points (a) and (b), of Regulation (EU) 2020/852. |
5. | Institutions shall disclose this information with first reference date as of 31 December 2023 that is the first disclosure reference date for the information on the GAR as referred to in Delegated Regulation (EU) 2021/2178.
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Template 8 – GAR (%)
1. | Institutions shall use the following instructions to disclose the information required in ‘Template 8 – GAR (%)’, as set out in Annex XXXIX to this Regulation. |
2. | Based on the information included in template 7, institutions shall disclose in this template the GAR as referred to in Delegated Regulation (EU) 2021/2178. |
3. | The purpose of this template is to show to what extent institutions’ activities qualify as environmentally sustainable in accordance with Articles 3 and 9 of Regulation (EU) 2020/852 so that stakeholders can understand the actions put in place by the institutions to mitigate climate change transition and physical risks. |
4. | Delegated Regulation (EU) 2021/2178 requires institutions to estimate and disclose the GAR twice. Once, the disclosure is based on the turnover taxonomy alignment of the counterparty (for non-financial corporates) for those exposures the purpose of which is not to finance specific identified activities (general purpose lending). A second disclosure is based on the CapEx alignment to Regulation (EU) 2020/852 of the counterparty for the same general purpose lending exposures. In this template, institutions shall only disclose the GAR once, based on the turnover alignment of the counterparty for the general purpose lending part only. |
5. | Institutions shall start disclosing this information with first reference date as of 31 December 2023, which is in line with the first reference date for the disclosure of the information on the GAR referred to in Delegated Regulation (EU) 2021/2178.
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Template 9 – Mitigating actions: BTAR
1. | Article 9 of Implementing Regulation (EU) 2021/2178 provides that the Commission reviews the application of that Regulation by 30 June 2024. The Commission is to assess in particular the need for any further amendments with regards to the inclusion of: exposures to central governments and central banks in the numerator and denominator of key performance indicators of financial undertakings; exposures to undertakings that do not publish a non-financial statement pursuant to Articles 19a or 29a of Directive 2013/34/EU in the numerator of key performance indicators of financial undertakings. |
2. | Institutions may choose to include in this template the following information. For those counterparties that are non-financial corporates and do not have disclosure obligations, institutions may disclose, on a reasonable effort basis and based on information already available and collected on a voluntary and bilateral basis from their counterparties or calculated using estimates, extended information on the taxonomy eligibility and taxonomy alignment as referred to in Regulation (EU) 2020/852 with regard to the environmental objectives of climate-change mitigation and adaptation, as referred to in Article 9, points (a) and (b), of Regulation (EU) 2020/852, of those exposures towards European non-financial corporations that are not subject to the disclosure obligations laid down in Directive 2013/34/EU and non-European non-financial corporations not subject to the disclosure obligations laid down in Directive 2013/34/EU. That information may be disclosed only once, based on counterparties’ turnover alignment for the general-purpose lending loans, as in the case of the GAR. The first disclosure reference date of this template is as of 31 December 2024. Institutions are not required to disclose this information before 1 January 2025. |
Template 9.1 – Mitigating actions: Assets for the calculation of BTAR
1. | Institutions may disclose in this template the gross carrying among of the assets relevant for the calculation of the BTAR. This template shall only apply to counterparties that are not subject to disclosure obligations.
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Template 9.2 – BTAR %
Institutions may disclose in this template the percentage of BTAR assets as disclosed in template 1 compared to the total assets in the denominator of the BTAR as disclosed in row 17 of template 9.1.
Template 9.3 – BTAR %
This template contains a summary of the BTAR KPI, breakdown by climate change environmental objective, and total, and with the breakdown for stock and flow.
Template 10 – Other climate change mitigating actions that are not covered in Regulation (EU) 2020/852
1. | This template covers other climate change mitigating actions and includes exposures of the institutions that are not taxonomy-aligned as referred to in Regulation (EU) 2020/852 according to templates 7 and 8 but that still support counterparties in the transition and adaptation process for the objectives of climate change mitigation and climate change adaptation. Those mitigating actions and activities shall include bonds and loans issued under standards other than the Union standards, including green bonds; sustainable bonds that are linked to aspects on climate change; sustainability-linked bonds that are linked to aspects on climate change; green loans; sustainability-linked loans that are linked to aspects on climate change; sustainability-linked loans that are linked to aspects on climate change. |
2. | Institutions shall include in the narrative accompanying this template detailed explanations on the nature and type of mitigating actions reflected in this template, including information on the type of risks that they aim to mitigate, climate change objectives that they support and information on the related counterparties and the timing of the actions. They shall also explain why those exposures are not fully aligned with the criteria laid down in Regulation (EU) 2020/852, and are not sustainable in accordance with Regulation (EU) 2020/852 but still contribute towards mitigating climate change risk transition or physical risk, as well as any other relevant information that may help understand the risk management framework of the institution. |
3. | Institutions shall start disclosing the information included in the templates with first disclosure reference date as of 31 December 2022.
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(*1) OJ L 282, 19.10.2016, p. 4.
(*2) COM/2019/640 final.
(*3) Directive 2013/34/EU of the European Parliament and of the Council of 26 June 2013 on the annual financial statements, consolidated financial statements and related reports of certain types of undertakings, amending Directive 2006/43/EC of the European Parliament and of the Council and repealing Council Directives 78/660/EEC and 83/349/EEC (OJ L 182, 29.6.2013, p. 19).
(*4) Directive 2014/95/EU of the European Parliament and of the Council of 22 October 2014 amending Directive 2013/34/EU as regards disclosure of non-financial and diversity information by certain large undertakings and groups (OJ L 330, 15.11.2014, p. 1).
(*5) C/2019/4490 (OJ C 209, 20.6.2019, p. 1).
(*6) Recommendations of the Task Force on Climate-related Financial Disclosures, https://www.fsb-tcfd.org/recommendations.
(*7) United Nations Environment Programme Finance Initiative (UNEP FI), https://www.unepfi.org.;
(*8) Global Reporting Initiative Sustainability Reporting Standards, https://www.globalreporting.org/standards.
(*9) United Nations’ Principles for Responsible Investment (UNPRI), https://www.unpri.org.
(*10) Directive 2013/36/EU of the European Parliament and of the Council of 26 June 2013 on access to the activity of credit institutions and the prudential supervision of credit institutions and investment firms, amending Directive 2002/87/EC and repealing Directives 2006/48/EC and 2006/49/EC (OJ L 176, 27.6.2013, p. 338).
(*11) Regulation (EC) No 1893/2006 of the European Parliament and of the Council of 20 December 2006 establishing the statistical classification of economic activities NACE Revision 2 and amending Council Regulation (EEC) No 3037/90 as well as certain EC Regulations on specific statistical domains (OJ L 393, 30.12.2006, p. 1).
(*12) Commission Delegated Regulation (EU) 2020/1818 of 17 July 2020 supplementing Regulation (EU) 2016/1011 of the European Parliament and of the Council as regards minimum standards for EU Climate Transition Benchmarks and EU Paris-aligned Benchmarks (OJ L 406, 3.12.2020, p. 17).
(*13) Council Directive 86/635/EEC of 8 December 1986 on the annual accounts and consolidated accounts of banks and other financial institutions (OJ L 372, 31.12.1986, p. 1).
(*14) https://carbonaccountingfinancials.com/standard.
(*15) https://www.cdp.net/en.
(*16) Directive 2010/31/EU of the European Parliament and of the Council of 19 May 2010 on the energy performance of buildings (OJ L 153, 18.6.2010, p. 13).
(*17) Directive 2012/27/EU of the European Parliament and of the Council of 25 October 2012 on energy efficiency, amending Directives 2009/125/EC and 2010/30/EU and repealing Directives 2004/8/EC and 2006/32/EC (OJ L 315, 14.11.2012, p. 1).
(*18) Net Zero Emissions by 2050 Scenario (NZE) –IEA (2021), World Energy Model, IEA, Paris https://www.iea.org/reports/world-energy-model
(*19) 2021 report can be found under this link.
(*20) For more examples, please refer to the UNEP FI and Acclimatise report: "Chartering New Climate. State-of-the-art tools and data for banks to assess credit risks and opportunities from physical climate change impacts”, September 2020, https://www.unepfi.org/publications/banking-publications/charting-a-new-climate/ The report provides detailed information with regard to time periods covered, use of future scenarios, spatial resolution and coverage, format of outputs to be received from particular datasets as well as licensing and cost (please note that most portals and databases offer free-to-use access). Moreover, the report elaborates on different techniques of physical risk assessment and measurement, like e.g. heat mapping, correlation analysis, dedicated tools and analytics.
(*21) Commission Delegated Regulation (EU) 2021/2178 of 6 July 2021 supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council by specifying the content and presentation of information to be disclosed by undertakings subject to Articles 19a or 29a of Directive 2013/34/EU concerning environmentally sustainable economic activities, and specifying the methodology to comply with that disclosure obligation (OJ L 443, 10.12.2021, p. 9).
(*22) Commission Delegated Regulation (EU) 2021/2139 of 4 June 2021 supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council by establishing the technical screening criteria for determining the conditions under which an economic activity qualifies as contributing substantially to climate change mitigation or climate change adaptation and for determining whether that economic activity causes no significant harm to any of the other environmental objectives (OJ L 442, 9.12.2021, p. 1).