EBA Issues Opinion as No-Action Letter on the Application of Provisions Relating to Disclosures on ESG Risks

On 5 August 2025, the European Banking Authority (EBA) issued an Opinion – submitted to the European Commission’s Directorate-General for Financial Stability, Financial Services and Capital Markets Union (DG FISMA) as a No-Action letter – addressing the application of Pillar III ESG disclosure requirements under the EBA disclosure Implementing Technical Standards (ITS).

The Opinion is issued in light of the uncertainties surrounding the implementation timeline of the revised ESG disclosure requirements under the Capital Requirements Regulation and the Omnibus proposal package.

The EBA’s Recommendations in Brief

In its Opinion, the EBA recommends that, for the period starting from 30 June 2025 until the amendments to the EBA disclosure ITS are adopted and enter into force:

  1. for large institutions that have issued securities that are admitted to trading in a regulated market of any Member State, competent authorities do not prioritise the enforcement of:
    1. the disclosure of templates EU 6 to EU 10; Template 1 column c; and Template 4, column c of Commission Implementing Regulation (EU) 2024/3172;
    2. the collection of templates EU 6 to EU 10; Template 1 column c; and Template 4, column c of EBA Decision EBA/DC/498 of 6 July 2023.
  2. for all other institutions not covered under point (a) above, competent authorities do not prioritise the enforcement of the disclosure of the corresponding ESG-risk disclosure templates, as applicable for each institution type in accordance with Commission Implementing Regulation (EU) 2024/3172.
 

Through the Opinion, The EBA intends to reduce the operational burden for institutions amid the evolving EU sustainability regulations, highlighting the importance of clarity and consistency in ESG disclosures.

Since the launch of the ENGAGE for ESG initiative in November 2022, the EU ESG regulatory landscape has evolved significantly. The ENGAGE Consortium is steadily monitoring regulatory changes and aims to develop the ENGAGE Solutions alongside such changes to ensure alignment with new requirements as they arise.

To read the EBA’s press release, please click the button below.