The European Banking Authority published a no-action letter on the application of ESG Pillar 3 disclosure requirements under its disclosure implementing technical standards, aiming to reduce legal and operational uncertainty as the EU sustainability reporting framework evolves under the European Commission’s Omnibus legislative package. It also released an updated ESG risk dashboard for EU/EEA banks using December 2024 data. Until the EBA’s amended disclosure implementing technical standards consulted on in May 2025 enter into force, the letter recommends that competent authorities do not prioritise enforcement of templates EU 6 to EU 10 and specified columns in Templates 1 and 4 in Commission Implementing Regulation (EU) 2024/3172 for large institutions with listed securities, and likewise do not prioritise enforcement of collecting the same items under EBA Decision EBA/DC/498 for those firms. Supervisors are also advised not to prioritise enforcement of the corresponding templates under Implementing Regulation (EU) 2024/3172 for other institutions newly brought into scope of Article 449a of the Capital Requirements Regulation, which was expanded to all institutions by CRR3 with application from 1 January 2025. The dashboard update characterises the ESG risk landscape as stable and indicates that future editions will be adjusted in line with the no-action letter.
European Banking Authority 2025-08-06
European Banking Authority issues no-action letter asking supervisors not to prioritise enforcement of selected ESG Pillar 3 disclosure templates and updates ESG risk dashboard
The European Banking Authority (EBA) issued a no-action letter on ESG Pillar 3 disclosure requirements to address legal and operational uncertainty amid evolving EU sustainability reporting frameworks. The letter advises against enforcing specific templates and columns for large institutions and newly scoped entities under the Capital Requirements Regulation. Additionally, the EBA updated its ESG risk dashboard, noting a stable risk landscape and future adjustments aligned with the no-action letter.