1) Colum IJ in Template 1 of Annex 1 to Implementing Regulation (EU) 2022/2453 requires disclosing the GHG financed emissions of the institution. This implies that the GHG emissions from the counterparties should be allocated to the investments held by the institution in a way that reflects its share in the total funding received by the counterparty. As of today, there is no standardized method to carry out this allocation however the methodology and data source(s) should be explained in the narrative part.

2) As highlighted in the instructions, institutions shall explain whether they are disclosing:

(i)            reported emissions (emissions are collected from the borrower or investee company directly);

(ii)           physical activity-based emissions (emissions are estimated by the reporting financial institution based on primary physical activity data collected from the borrower or investee), and/or

(iii)          economic activity-based emissions (emissions are estimated by the reporting financial institution based on economic activity data collected from the borrower or investee company).

Institutions may especially use “sector average intensity emissions intensity” to estimate the counterparties’ GHG emissions when they are not able to collect directly their reported emissions but are able to collect or to estimate physical or economic activity data.

3) Column IJ includes the total GHG financed emissions which includes the scope 1, scope 2 and scope 3 emissions of the counterparties allocated to the investments held by the institution. As highlighted in the instructions, “where data and methodological challenges exist, banks shall follow the GHG protocol and its 15 stages, both upstream and downstream, as presented in the Commission Guidelines on non-financial reporting: supplement on reporting climate related information.”