Question ID: 3038
Regulation Reference: (EU) 2023/894 - ITS with regard to the templates for the submission of information necessary for supervision
Topic: Reporting Templates
Template: S.06.04
Status: Final
Date of submission: 15 Mar 2024
Question
Can you please provide clarification as to why only NACE sections A to N, as prescribed in S.06.02 have been identified as needing to be reported in S.06.04 R0010. Are there any specific reference to a regulation which identifies a need to exclude sectors O- T
Background of the question
I'm trying to understand why a certain selection of NACE codes (A-N) have been identified as being more exposed to transition risk
EIOPA answer
Template S.06.02 requires (C0230) reporting of NACE codes A to N at four-digit level. S.06.04 asks for the identification of investments exposed to transition risk to be consistent with the classification made and reported through the four-digit level NACE codes for NACE sections A to N, as prescribed in S.06.02.
NACE sections A to N include sectors of economic activities which, based on currently available research and analysis may be likely exposed to climate change-related transition risk. This reflects the methodology by Battiston, which at most aggregate level identifies Climate Policy Relevant Sectors (CPRS) to include activities in NACE sectors A, B, C, D, F, H, as well as G, I, L, M. EIOPA's early analysis on transition risk used the distribution of emission intensity according to NACE and CPRS , which includes activities under NACE B, C, D, F, H, I, L . Based on the latest NACE 2.1 classification applicable from 2025 NACA A to N still relevant in this respect.
Undertakings are however free to identify investments that are potentially subject to transition risk under other NACE codes, and sectors O-T are not excluded.