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1 min readWarningEBA reporting framework 4.2Updated 10 November 2026

Towards taxonomy relevant sectors (taxonomy-eligible), total (CCM + CCA) must equal the sum of its two parts (D 09.01, EBA rule v89368_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

For towards taxonomy relevant sectors (taxonomy-eligible): total (CCM + CCA) must equal climate change mitigation (CCM) plus climate change Adaptation (CCA).

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

EU Non-financial corporations (not subject to NFRD disclosure obligations), TOTAL (CCM + CCA), of which towards taxonomy relevant sectors (Taxonomy-eligible) = EU Non-financial corporations (not subject to NFRD disclosure obligations), Climate Change Mitigation (CCM), of which towards taxonomy relevant sectors (Taxonomy-eligible) + EU Non-financial corporations (not subject to NFRD disclosure obligations), Climate Change Adaptation (CCA), of which towards taxonomy relevant sectors (Taxonomy-eligible)

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  3. 03If they differ, a part is missing, a value sits in the wrong cell, or the total is out of date.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)
  • 0030Loans and advances
  • 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)
  • 0070Of which towards taxonomy relevant sectors (Taxonomy-eligible)
  • 0120Of which towards taxonomy relevant sectors (Taxonomy-eligible)

A worked example

The first of its checks, with simple numbers.

Illustrative values
towards taxonomy relevant sectors (taxonomy-eligible), climate change mitigation (CCM)1,200
towards taxonomy relevant sectors (taxonomy-eligible), climate change Adaptation (CCA)800
Together2,000
What the rule then expects

Towards taxonomy relevant sectors (taxonomy-eligible), total (CCM + CCA) must then be 2,000.

2,000Passes
2,100Fails

A file that reports 2,000 passes. One that reports 2,100 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,r0020,c0120,} = {D_09.01,r0020,c0020,} + {D_09.01,r0020,c0070,}

The next five:

{D_09.01,r0090,c0120,} = {D_09.01,r0090,c0020,} + {D_09.01,r0090,c0070,}{D_09.01,r0100,c0120,} = {D_09.01,r0100,c0020,} + {D_09.01,r0100,c0070,}{D_09.01,r0060,c0120,} = {D_09.01,r0060,c0020,} + {D_09.01,r0060,c0070,}{D_09.01,r0110,c0120,} = {D_09.01,r0110,c0020,} + {D_09.01,r0110,c0070,}{D_09.01,r0030,c0120,} = {D_09.01,r0030,c0020,} + {D_09.01,r0030,c0070,}

And 4 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.