Tailored approach: Small and medium-sized banks gain simplified ESG reporting obligations; large listed banks face no new requirements.
Implementation support: Transitional measures and supervisory flexibility will help institutions adapt to new disclosures.
Alignment with EU taxonomy: Updates align ESG disclosure templates with the Green Asset Ratio and EU sustainability taxonomy.
The European Banking Authority (EBA) has launched a public consultation to amend ESG disclosure requirements under the CRR3 framework, aiming to simplify compliance while enhancing transparency and consistency.
This initiative supports the European Commission’s omnibus proposal to cut reporting costs and streamline sustainability reporting. The revised framework proposes a proportionate approach based on institution size, complexity, and listing status, offering simplified requirements for smaller and non-listed banks. For large listed banks, no new ESG obligations are introduced.
“This proposal specifies enhanced and proportionate disclosure requirements related to ESG-related risks, equity exposures and aggregate exposure to shadow banking entities.”
The amended disclosure rules expand the scope of ESG risk disclosures to all institutions and refine the reporting process for shadow banking and equity exposures. The EBA is also incorporating updated statistical codes (NACE) and adjusting the Green Asset Ratio (GAR) templates to ensure permanent alignment with the EU Taxonomy Regulation.
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“The EBA has designed a proportionate approach for ESG disclosures based on the institution’s type, size and complexity.”
To ease adoption, the EBA proposes transitional provisions and supervisory flexibility. These include a “no-action” letter advising regulators not to prioritize enforcement of specific ESG disclosure templates during the transition phase, particularly for large and listed institutions.
“To clarify expectations, ensure consistency and reduce operational burden… the EBA is encouraging supervisory flexibility.”
Additionally, the EBA is updating its mapping tool to help banks align their Pillar 3 disclosures with supervisory reporting, facilitating clearer and more consistent communication of ESG risk.
The consultation is open until 22 August 2025.
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