1 min readWarningEBA reporting framework 4.2Updated 10 November 2026

None of the 120 values it checks in mitigating actions can be negative (D 09.01, EBA rule v12834_s)

A warning in the environmental, social and governance risks return (ESG), on template D 09.01, mitigating actions: assets for the calculation of BTAR.

The rule in plain words

None of the values it checks in mitigating actions can be negative.

EBA checks it for ten columns, from towards taxonomy relevant sectors (taxonomy-eligible) (0020) to enabling environmentally sustainable (taxonomy-aligned) (0160). And for twelve rows, from total GAR assets (0010) to total BTAR assets (0120). That makes 120 checks. A failure names the one that failed.

How the Line4 Check report words itShow

The first of its checks, word for word as the report shows it when it fails. The others read the same, with their own column, row or sheet.

Of which towards taxonomy relevant sectors (Taxonomy-eligible): Total GAR Assets >= 0

What to do if your filing fails it

  1. 01Open the template below and find the cells the rule reads.
  2. 02Look for a value with the wrong sign in these cells, such as an amount entered as a negative number.
  3. 03EBA compares the values exactly here: there is no rounding tolerance.
  4. 04It runs only when your filing indicators mark D 09.01 as reported.
  5. 05This is a warning. It does not stop the filing on its own, but your authority may ask you to explain it.

The cells it reads

Mitigating actions: assets for the calculation of BTAR (D 09.01)

Rows

  • 0010Total GAR Assets
  • 0020EU Non-financial corporations (not subject to NFRD disclosure obligations)
  • 0030Loans and advances
  • 0040Of which loans collateralised by commercial immovable property
  • 0050Of which building renovation loans
  • 0060Debt securities
  • 0070Equity instruments
  • 0080Non-EU Non-financial corporations (not subject to NFRD disclosure obligations)
  • 0090Loans and advances
  • 0100Debt securities
  • 0110Equity instruments
  • 0120TOTAL BTAR ASSETS

Columns

  • 0020Of which towards taxonomy relevant sectors (Taxonomy-eligible)
  • 0030Of which environmentally sustainable (Taxonomy-aligned)
  • 0040Of which specialised lending
  • 0050Of which transitional
  • 0060Of which enabling
  • 0120Of which towards taxonomy relevant sectors (Taxonomy-eligible)
  • 0130Of which environmentally sustainable (Taxonomy-aligned)
  • 0140Of which specialised lending
  • 0150Of which transitional/adaptation
  • 0160Of which enabling

A worked example

The first of its checks, with simple numbers.

What the rule then expects

Total GAR assets, towards taxonomy relevant sectors (taxonomy-eligible) must then be at least 0.

0Passes
-100Fails

A file that reports 0 passes. One that reports -100 fails, by 100.

The numbers are illustrative.

Show the rule as writtenShow

EBA's formula, as written out for the first of its checks. Cells are written as {template, row, column, sheet}.

{D_09.01,r0010,c0020,} >= 0

The next five:

{D_09.01,r0010,c0030,} >= 0{D_09.01,r0010,c0040,} >= 0{D_09.01,r0010,c0050,} >= 0{D_09.01,r0010,c0060,} >= 0{D_09.01,r0010,c0120,} >= 0

And 114 more, the same formula for the other cells it covers.

Every ESG rule, by template

Checks like this one, run at the point of submission, are the first step to real-time supervision.