The European Banking Authority (EBA) has issued a no-action letter clarifying the application of ESG Pillar 3 disclosure requirements, aiming to address legal and operational uncertainties amid ongoing regulatory changes.
The move comes as the European Commission progresses with its Omnibus legislative package on sustainability reporting, which is set to amend the EBA’s disclosure Implementing Technical Standards (ITS). Alongside this, the EBA has released an updated ESG risk dashboard using data from December 2024.
The no-action letter formalises earlier guidance given in the EBA’s May 2025 Consultation Paper on the amending ITS for Pillar 3 disclosures. It provides clear recommendations to competent authorities until the new ITS takes effect. Specifically, the EBA advises against prioritising enforcement for certain ESG disclosure templates—namely EU 6 to EU 10 and specific columns in Templates 1 and 4—under the Commission’s Implementing Regulation (EU) 2024/3172. This applies both to large institutions with listed securities and to other institutions that have recently been brought under the scope of Article 449a of the Capital Requirements Regulation (CRR).
Authorities are also urged not to prioritise the collection of these templates under the EBA’s Decision EBA/DC/498 of 6 July 2023 for large listed institutions. The guidance is intended to give banks and regulators breathing room to adapt to the evolving ESG disclosure framework while maintaining overall transparency and compliance.
The EBA emphasised that it remains committed to developing a coherent and streamlined ESG disclosure regime, working closely with EU institutions and stakeholders to ensure smooth adoption of the new requirements. The no-action letter is intended to reduce uncertainty and ensure that reporting expectations are aligned with the forthcoming legislative changes.
The updated ESG risk dashboard indicates that the ESG risk profile across EU/EEA banks remains stable, reflecting the long-term nature of climate-related risks and the gradual transition within banking portfolios. The EBA noted that the dashboard’s content will be modified in future editions to reflect the new approach outlined in the no-action letter, particularly the recommendations not to enforce the specified templates and disclosures in the short term.
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