1 min readSwitched off by EBAEBA reporting framework 4.2Updated 10 November 2026

EU non-financial corporations (not subject to NFRD disclosure obligations) must equal the sum of its three parts (D 09.01, EBA rule v23942_h)

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

EBA switched this rule off in its 4.2 severity package (January 2026), so it does not run on reporting framework 4.2 filings. EBA's list of validation rules of 12 October 2026 still has it switched off. Line4 Check does not run it either.

The rule in plain words

EU non-financial corporations (not subject to NFRD disclosure obligations) must equal these three added up:

  • Equity instruments
  • Debt securities
  • Loans and advances

All the values are in the towards taxonomy relevant sectors (taxonomy-eligible) column (0120) of D 09.01.

EBA writes it out 16 times. These words are for the first; the others are the same rule on other cells.

The template it checks

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

Rows

  • 0020EU Non-financial corporations (not subject to NFRD disclosure obligations)
  • 0030Loans and advances
  • 0060Debt securities
  • 0070Equity instruments

Column

  • 0120Of which towards taxonomy relevant sectors (Taxonomy-eligible)
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,r0020,c0120,} = {D_09.01,r0070,c0120,} + {D_09.01,r0060,c0120,} + {D_09.01,r0030,c0120,}

And 15 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.