The European Banking Federation submitted a response to the European Commission’s consultation on revised European Sustainability Reporting Standards and the voluntary standards, limited to the Commission’s proposed changes versus EFRAG’s version, backing EFRAG’s standards as an acceptable compromise, calling for a regulatory pause to assess implementation and inform any post-implementation review, and seeking clarifications on the practical application of the value chain cap, the treatment of sanctions and fines only after a final non-appealable decision, the evidence needed to support non-materiality conclusions in complex groups, and flexibility in data sourcing where counterparty-level information is unavailable.