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3 min readWarningEBA reporting framework 4.2Updated 10 November 2026

GHG financed emissions (scope 1, scope 2 and scope 3 emissions of the counterparty) (in tons of CO2 equivalent) cannot be less than scope 3 financed emissions (EBA rule v89318_m)

A warning in the environmental, social and governance risks return (ESG), on template D 01.00, banking book- Indicators of potential climate change transition risk: credit quality of exposures by sector, emissions and residual maturity.

Check your file against this ruleWhat to do if it fails

The rule in plain words

GHG financed emissions (scope 1, scope 2 and scope 3 emissions of the counterparty) (in tons of CO2 equivalent) cannot be less than scope 3 financed emissions.

EBA checks it for 51 rows, from exposures towards sectors that highly contribute to climate change (0010) to total (0560). That makes 51 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.

C.27 - Manufacture of electrical equipment, GHG financed emissions (scope 1, scope 2 and scope 3 emissions of the counterparty) (in tons of CO2 equivalent) >= C.27 - Manufacture of electrical equipment, Of which Scope 3 financed emissions

What to do if your filing fails it

  1. 01Open the template below and find the cells the rule reads.
  2. 02Compare the values in your file. If the first is smaller than it may be, one of them is wrong: check both before you change either.
  3. 03EBA allows a small rounding difference, worked out from the decimals each value is reported with.
  4. 04It runs only when your filing indicators mark D 01.00 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

Banking book- Indicators of potential climate change transition risk: credit quality of exposures by sector, emissions and residual maturity (D 01.00)

Rows

  • 0010Exposures towards sectors that highly contribute to climate change
  • 0020A - Agriculture, forestry and fishing
  • 0030B - Mining and quarrying
  • 0040B.05 - Mining of coal and lignite
  • 0050B.06 - Extraction of crude petroleum and natural gas
  • 0060B.07 - Mining of metal ores
  • 0070B.08 - Other mining and quarrying
  • 0080B.09 - Mining support service activities
  • 0090C - Manufacturing
  • 0100C.10 - Manufacture of food products
  • 0110C.11 - Manufacture of beverages
  • 0120C.12 - Manufacture of tobacco products
  • 0130C.13 - Manufacture of textiles
  • 0140C.14 - Manufacture of wearing apparel
  • 0150C.15 - Manufacture of leather and related products
  • 0160C.16 - Manufacture of wood and of products of wood and cork, except furniture; manufacture of articles of straw and plaiting materials
  • 0170C.17 - Manufacture of paper and paper products
  • 0180C.18 - Printing and reproduction of recorded media
  • 0190C.19 - Manufacture of coke and refined petroleum products
  • 0200C.20 - Manufacture of chemicals and chemical products
  • 0220C.22 - Manufacture of rubber products
  • 0230C.23 - Manufacture of other non-metallic mineral products
  • 0240C.24 - Manufacture of basic metals
  • 0250C.25 - Manufacture of fabricated metal products, except machinery and equipment
  • 0260C.26 - Manufacture of computer, electronic and optical products
  • 0270C.27 - Manufacture of electrical equipment
  • 0280C.28 - Manufacture of machinery and equipment n.e.c.
  • 0290C.29 - Manufacture of motor vehicles, trailers and semi-trailers
  • 0300C.30 - Manufacture of other transport equipment
  • 0310C.31 - Manufacture of furniture
  • 0320C.32 - Other manufacturing
  • 0330C.33 - Repair and installation of machinery and equipment
  • 0340D - Electricity, gas, steam and air conditioning supply
  • 0350D35.1 - Electric power generation, transmission and distribution
  • 0360D35.11 - Production of electricity
  • 0370D35.2 - Manufacture of gas; distribution of gaseous fuels through mains
  • 0380D35.3 - Steam and air conditioning supply
  • 0390E - Water supply; sewerage, waste management and remediation activities
  • 0400F - Construction
  • 0410F.41 - Construction of buildings

And 11 more.

Columns

  • 0090GHG financed emissions (scope 1, scope 2 and scope 3 emissions of the counterparty) (in tons of CO2 equivalent)
  • 0100Of which Scope 3 financed emissions

A worked example

The first of its checks, with simple numbers.

Illustrative values
GHG financed emissions (scope 1, scope 2 and scope 3 emissions of the counterparty) (in tons of CO2 equivalent)1,200
What the rule then expects

Scope 3 financed emissions can then be at most 1,200.

1,200Passes
1,300Fails

A file that reports 1,200 passes. One that reports 1,300 fails, by 100.

The numbers are illustrative, reported to the unit, so the rounding tolerance does not change the result.

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_01.00,r0270,c0090,} >= {D_01.00,r0270,c0100,}

The next five:

{D_01.00,r0090,c0090,} >= {D_01.00,r0090,c0100,}{D_01.00,r0050,c0090,} >= {D_01.00,r0050,c0100,}{D_01.00,r0110,c0090,} >= {D_01.00,r0110,c0100,}{D_01.00,r0060,c0090,} >= {D_01.00,r0060,c0100,}{D_01.00,r0400,c0090,} >= {D_01.00,r0400,c0100,}

And 45 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.