EBA supervisory reporting simplification: impact on ESG reporting

^{Full approach}

^{Simplified approach}

^Template

^{Large institutions}

^{Other listed institutions + Large subsidiaries}

^{SNCI + Other non-listed institutions}

^{Areas which have expanded from corresponding Pillar 3 disclosure template}

^{D 01.00: Climate Change transition risk: Credit quality of exposures by sector, emissions and residual maturity}

^{Semi-annual (for large institutions with total assets >= 30 bn EUR)}

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^{Additional data points have been introduced for supervisory reporting purposes to enable more granular risk analysis and to meet specific stress test data requirements. Certain data points have also been incorporated with a view to further simplifying and streamlining FINREP reporting, by reducing overlaps and improving consistency across supervisory data collections.}

^{The template has been further expanded to enhance its suitability for supervisory risk assessment and monitoring. In particular, it now incorporates information on gross interest income and gross fee and commission income, allowing supervisors to better assess the relevance of ESG risk exposures in terms of income generation.}

^{Information on ‘off-balance sheet exposures’ has also been added to allow for comprehensive assessment of all possible risk exposures.}

^{In addition, the sectoral breakdown in the rows has been extended with more granular NACE codes to ensure that information on exposures towards fossil fuel sectors can be identified.}

^{Finally, the template includes information not only on NACE sectors but also on country breakdown, the latter for the amortised cost portfolios.} 

^{D 01.02: Climate Change transition risk: Credit quality of exposures by sector, emissions and residual maturity (subset of D 01.00)}

^{Semi-annual (for large institutions with total assets < 30 bn EUR)}

^Annual

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^{D 01.01 Template 1A: Transition and physical risk}

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^Annual

^{Additional columns have been included:}

^{Off balance sheet items, to provide a more comprehensive view of institutions’ exposures, consistent with the supervisory objective of capturing risks beyond the balance sheet.}

^{“Accumulated impairment accumulated negative changes in fair value due to credit risk”, added to support a simplified yet complete reporting framework and to facilitate the planned simplification of some Finrep templates.}

^{D 02.00: Climate change transition risk: Loans collateralised by immovable property - Energy performance of the collateral}

^Semi-annual

^Annual

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^{This template is largely unchanged, with only a few additional elements added:}

^{Column on ‘Of which loans with an improvement of the energy efficiency of the collateral compared with the previous periods’, this column aims to allow the assessment of the efficiency of banks’ strategies for reducing transition risk in their mortgage portfolios.}

^{A new row “of which: part of a cover pool of covered bonds’ for total EU and non-EU exposures has been added.}

^{D 03.00: Indicators of potential climate change transition risk: emission intensity per physical output and by sector}

^Annual

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^{Two additional columns have been introduced for supervisory reporting purposes in relation to internal short-term targets, enabling supervisors to better understand institutions’ internal strategies, planning horizons, and risk management approaches.}

^{D 04.00: Environment-related concentration risk (NEW)}

^Semi-annual

^Annual

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^{This new template will replace existing  template 4 on concentration of exposures towards top 20 polluting companies. It will be only part of supervisory reporting, and not of Pillar 3, as it will include obligor level information.}

^{D 05 00: Climate change physical risk: Exposures subject to physical risk}

^Semi-annual

^{The template has been expanded to include off‑balance‑sheet exposures, to have a complete view of physical‑risk exposures.} 

^{Under the Pillar 3 framework, only the aggregate amount of exposures subject to material physical risk shall be disclosed. For supervisory reporting purposes, a more detailed breakdown is considered necessary to allow for enhanced analysis and risk assessment. Therefore, within the total exposures subject to material physical risk, two further columns “of which highly exposed” and “of which moderately exposed” are proposed.} 

^{D 05.01: Climate change physical risk: Exposures subject to physical risk}

^Annual

^{Off-balance-sheet items subject to physical risk’, has been included to provide a more comprehensive view of institutions’ exposures, consistent with the supervisory objective of capturing risks beyond the balance sheet.}

^{D 10.00: Mitigating actions: Exposures contributing to sustainability objectives}

^Annual

^Annual

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^{No structural changes, additional data points, or modifications have been introduced for supervisory reporting purposes.}

^{D 11.00: Banking book- Exposures to environmental risks (beyond climate) - Physical and transition risks (NEW)}

^Annual

^Annual

^{This new template structures information around the two key channels through which environmental risks materialise: (i) environmental impacts, capturing where a counterparty’s activities negatively affect nature (e.g. land, freshwater and ocean use change; pollution; overexploitation; invasive species); and (ii) ecosystem service dependencies, capturing where a counterparty relies on natural systems (e.g. water supply; provisioning; regulating; supporting or cultural services) for its operations. This approach, aligned with Task Force on Nature-related Financial Disclosures (TNFD) and NGFS guidance, enables supervisors to identify exposures vulnerable to the degradation of natural systems or to transition measures aimed at protecting and restoring biodiversity.}