On 9 July 2025, the European Banking Authority (EBA) published a consultation paper on the revision of the guidelines on product oversight and governance arrangements for retail banking products to take into account products with ESG features and greenwashing risks.
Background
In 2015, the EBA issued Product Oversight and Governance Guidelines (POG Guidelines) which were intended to regulate the internal processes, functions and strategies aimed at designing retail banking products, bringing them to market, and reviewing them over their life cycle.
The Capital Requirements Directive IV and the Capital Requirements Regulation were amended regarding Environmental, Social and Governance (ESG) risks, to include new provisions and change existing ones, including requirements that form one of the legal bases of the POG Guidelines.
Given these developments the EBA has concluded that a revision of the POG Guidelines of retail banking products is needed with the aim of making more explicit in the existing requirements ESG and greenwashing considerations as and when products with ESG features are offered and sold to consumers.
Targeted approach
The consultation paper proposes a targeted approach, adjusting only a limited number of existing requirements in the POG Guidelines related to the subject matter, manufacturer’s internal control functions, the target market, distribution channels, information for distributors and information and support for the manufacturer’s arrangements.
Next steps
The deadline for comments on the consultation paper is 9 October 2025.
A virtual public hearing on the consultation paper will be held on 11 September 2025. Dial in details will be communicated to those who have registered by 8 September 2025.
The EBA expects to publish its final guidelines in Q1 2026, which will be applied as of 1 December 2026.