Question ID
2024_7272
Legal act
Regulation (EU) No 575/2013 (CRR)
Topic
Transparency and Pillar 3
Article
449a
Paragraph
Template 8
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Regulation (EU) 2022/2453 - ITS on ESG disclosures
Article/Paragraph
Template 8
Type of submitter
Other
Subject matter
Denominator for GAR Green Asset Ratio (%) Calculation
Question

Which denominator should be used in the GAR KPI templates:

  • the corresponding Total gross carrying amount (column a) of the respective rows in template 7 "Mitigating actions: Assets for the calculation of GAR", (for example if the GAR is computed for line 0020 'Loans and advances, debt securities and equity instruments not HfT eligible for GAR calculation' in case of numerator is used the loans and advances, for example Of which environmentally sustainable Taxonomy-aligned, and in the denominator should be the similarly filtered Total gross carrying amount from the same row of template 7;
  • The denominator should be unique, disregarding the formula level: "Total GAR assets" line 320  or 
  • The denominator should be unique, disregarding the formula level: "Total assets in the denominator (GAR)" line 0450 ?
Background on the question

According to the "Annex XL - Instructions for disclosure of ESG risk", the denominator for KPI's in Template 8 - GAR (%) "The denominator of the KPI shall be the gross carrying amount of covered assets as defined in the instructions corresponding to column ‘a’ of Template 7.". 

However, in the Commission Delegated Regulation (EU) 2021/2178, the following information is provided related to denominator: 

Annex V 1.2.1.2., "The denominator shall be the total gross carrying amount of loans and advances, debt securities and equity holdings of relevant accounting portfolios in financial undertakings."

Annex V 1.2.1.3.1.1. "The denominator shall include the total gross carrying amount of loans to households collateralised by residential property plus the total gross carrying amount of house renovation loans to households, avoiding double counting of loans in case that the latter are collateralised loans."

Annex V 1.2.1.5. "The denominator shall include the total gross carrying amount of held-for-sale commercial and residential real estate collaterals repossessed by the credit institution."

Annex V 1.2.3. "The denominator shall be the total amount of fees and commission income from undertakings from products or services other than lending and asset management."

Could you please confirm if the denominator should be unique or should it correspond to the total gross carrying amount (column a) of each specific row?

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because the issue it deals with is already explained in the instructions for Template 8 of Annex XL of Regulation (EU) 2021/637.

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Status
Rejected question