The European Banking Federation (EBF) has submitted a detailed response to EFRAG’s consultation on the revised Exposure Drafts of the European Sustainability Reporting Standards (ESRS), welcoming the simplifications made but calling for a more ambitious streamlining to avoid disproportionate reporting burdens for banks while preserving the most material information for users. Key recommendations include allowing banks to use both intensity and absolute greenhouse gas (GHG) emission reduction targets, without being required to convert intensity targets into absolute ones where this is not suitable; deleting the proposed “gross vs net” guidance on assessing positive and negative impacts as overly complex; and applying relief for missing data consistently across all disclosures, including GHG emissions where banks rely on client data and face major limitations in scope 3 coverage and quality. The EBF also calls for a clear definition of the “fair presentation” principle, potentially by explicitly referencing the International Sustainability Standards Board definition, and supports a phased approach to “anticipated financial effects” disclosures, favouring qualitative information for now while quantitative disclosures could be considered once reporting and audit practices mature. On value chain reporting, the EBF notes EFRAG has deferred solutions for financial institutions pending Level 1 discussions, but argues that if no Level 1 solution emerges, ESRS 1 should at minimum include a general provision allowing financial undertakings to adapt reporting to the specificities of financial institutions to meet relevance and reliability criteria. It further cautions that a reduction in mandatory data points may not translate into proportionate reductions in reporting effort where information remains required via other disclosures or where data points have been merged rather than removed.
European Banking Federation 2025-09-29
European Banking Federation urges EFRAG to further streamline ESRS sustainability reporting and better reflect banks’ specificities
The European Banking Federation (EBF) responded to EFRAG's consultation on revised European Sustainability Reporting Standards (ESRS), advocating for streamlined reporting to reduce banks' burdens while maintaining material information. Key recommendations include flexibility in GHG emission targets, consistent relief for missing data, and a phased approach to "anticipated financial effects" disclosures. The EBF emphasizes adaptable value chain reporting for financial institutions and cautions against assuming fewer data points will lessen reporting efforts.