1 min readWarningEBA reporting framework 4.2Updated 10 November 2026

Environmentally sustainable (taxonomy-aligned) cannot be less than specialised lending (D 09.01, EBA rule v89365_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.

The rule in plain words

Environmentally sustainable (taxonomy-aligned) cannot be less than specialised lending.

EBA checks it for twelve rows, from total GAR assets (0010) to total BTAR assets (0120). That makes twelve 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.

Loans and advances, Of which environmentally sustainable (Taxonomy-aligned) >= Loans and advances, Of which specialised lending

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 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

  • 0030Of which environmentally sustainable (Taxonomy-aligned)
  • 0040Of which specialised lending

A worked example

The first of its checks, with simple numbers.

Illustrative values
environmentally sustainable (taxonomy-aligned)1,200
What the rule then expects

Specialised lending 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_09.01,r0030,c0030,} >= {D_09.01,r0030,c0040,}

The next five:

{D_09.01,r0010,c0030,} >= {D_09.01,r0010,c0040,}{D_09.01,r0070,c0030,} >= {D_09.01,r0070,c0040,}{D_09.01,r0050,c0030,} >= {D_09.01,r0050,c0040,}{D_09.01,r0060,c0030,} >= {D_09.01,r0060,c0040,}{D_09.01,r0090,c0030,} >= {D_09.01,r0090,c0040,}

And 6 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.