On 22 May 2025 the European Banking Authority (EBA) launched a public consultation on proposed amendments to the European Commission’s Implementing Regulation on Pillar 3 disclosures under the CRR3. The consultation paper aims to enhance the transparency and consistency of disclosures, while simplifying the reporting process for institutions.
The EBA proposal specifies enhanced and proportionate disclosure requirements concerning ESG-related risks, equity exposures, and aggregate exposure to shadow banking entities. It also implements the new codes for the statistical classification of economic activities in the EU called NACE.
The consultation runs until 22 August 2025. A public hearing on this consultation will take place via conference call on 26 June 2025.
Regarding ESG-related risk disclosures and in line with the CRR3 mandate, the proposal extends the scope of institutions required to disclose ESG information, covering not only large listed institutions but also large non-listed institutions, SNCIs, and large subsidiaries. In alignment with the European Commission’s commitment to reduce reporting costs and simplify sustainability reporting, the EBA has designed a proportionate approach for ESG disclosures. The proposal includes:
1The ENGAGE for ESG consortium has created specific industry reporting standards related to residential mortgages and loans for home renovations to align with the EU Taxonomy Regulation. The ENGAGE Portal collects the relevant information from banks and lenders in dedicated private areas.
Template 7 from the ITS on the disclosure of assets for the calculation of the Green Asset Ratio (GAR) and template 8 on the percentage of the total assets covered, provide important information on how financial institutions are mitigating risks related to climate change.
In order to align with the requirements as set out in the Disclosures Delegated Act, the EBA proposes to replace templates 7 and 8 from the ITS on ESG disclosures with a cross-reference to the relevant templates in the Disclosures Delegated Act to guarantee the continuous alignment with those requirements. By doing so, the EBA intends to ensure that all relevant information is included in the prudential disclosure requirements and at the same time, consistency with the disclosures under the Taxonomy Regulation is ensured. The frequency of the templates would be annual.
In its consultation paper, the EBA also highlights the simplification effort announced through the Omnibus proposal. In particular, the European Commission’s consideration of relevant amendments to the GAR templates, reducing around the number of data points to be disclosed under the Taxonomy Regulation by 89%, and the introduction of a 10% de materiality threshold under which Taxonomy alignment does not need to be assessed.
For more information on the consultation, please visit the EBA website via the button below.
To achieve the proposed 55% emission reduction climate target by 2030, around EUR 275 billion of additional investments are needed per year.
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