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1 min readWarningEBA reporting framework 4.2Updated 10 November 2026

Total BTAR assets must equal the sum of its three parts (EBA rule v89359_m)

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

Check your file against this ruleWhat to do if it fails

The rule in plain words

Total BTAR assets must equal these three added up:

  • Non-EU non-financial corporations (not subject to NFRD disclosure obligations)
  • EU non-financial corporations (not subject to NFRD disclosure obligations)
  • Total GAR assets

EBA checks it for 16 columns, from total gross carrying amount (0010) to enabling environmentally sustainable (taxonomy-aligned) (0160). That makes 16 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.

Total gross carrying amount: TOTAL BTAR ASSETS = Non-EU Non-financial corporations (not subject to NFRD disclosure obligations) + EU Non-financial corporations (not subject to NFRD disclosure obligations) + Total GAR Assets

What to do if your filing fails it

  1. 01Open the template below and find the cells the rule reads.
  2. 02Add up the parts in your file and compare the result with the total.
  3. 03If they differ, a part is missing, a value sits in the wrong cell, or the total is out of date.
  4. 04EBA allows a small rounding difference, worked out from the decimals each value is reported with.
  5. 05It runs only when your filing indicators mark D 09.01 as reported.
  6. 06This 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)
  • 0080Non-EU Non-financial corporations (not subject to NFRD disclosure obligations)
  • 0120TOTAL BTAR ASSETS

Columns

  • 0010Total gross carrying amount
  • 0020Of which towards taxonomy relevant sectors (Taxonomy-eligible)
  • 0030Of which environmentally sustainable (Taxonomy-aligned)
  • 0040Of which specialised lending
  • 0050Of which transitional
  • 0060Of which enabling
  • 0070Of which towards taxonomy relevant sectors (Taxonomy-eligible)
  • 0080Of which environmentally sustainable (Taxonomy-aligned)
  • 0090Of which specialised lending
  • 0100Of which adaptation
  • 0110Of 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.

Illustrative values
Non-EU non-financial corporations (not subject to NFRD disclosure obligations)1,200
EU non-financial corporations (not subject to NFRD disclosure obligations)800
Total GAR assets450
Together2,450
What the rule then expects

Total BTAR assets must then be 2,450.

2,450Passes
2,550Fails

A file that reports 2,450 passes. One that reports 2,550 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_09.01,r0120,c0010,} = {D_09.01,r0080,c0010,} + {D_09.01,r0020,c0010,} + {D_09.01,r0010,c0010,}

The next five:

{D_09.01,r0120,c0140,} = {D_09.01,r0080,c0140,} + {D_09.01,r0020,c0140,} + {D_09.01,r0010,c0140,}{D_09.01,r0120,c0130,} = {D_09.01,r0080,c0130,} + {D_09.01,r0020,c0130,} + {D_09.01,r0010,c0130,}{D_09.01,r0120,c0040,} = {D_09.01,r0080,c0040,} + {D_09.01,r0020,c0040,} + {D_09.01,r0010,c0040,}{D_09.01,r0120,c0100,} = {D_09.01,r0080,c0100,} + {D_09.01,r0020,c0100,} + {D_09.01,r0010,c0100,}{D_09.01,r0120,c0160,} = {D_09.01,r0080,c0160,} + {D_09.01,r0020,c0160,} + {D_09.01,r0010,c0160,}

And 10 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.