On 6 August 2025, the European Banking Authority (EBA) published an opinion in the form of a no-action letter on the application of the provisions relating to disclosures on environmental, social and governance (ESG) risks.

Background

On 22 May 2025, the EBA issued a consultation paper on draft implementing technical standards (draft ITS) amending European Commission (Commission) Implementing Regulation (EU) 2024/3172. The proposals amend the Pillar 3 disclosures framework by incorporating the requirements set out in the Capital Requirements Regulation 3 (CRR 3) regarding ESG related risks, equity exposures and the aggregate exposure to shadow banking entities. The deadline for comments on the consultation paper is 22 August 2025.

The Commission’s Omnibus Package proposes substantive reforms in the areas of sustainable finance reporting, sustainability due diligence, and the EU Taxonomy. These legislative developments, particularly those related to the EU Taxonomy, have a direct impact on the structure and content of ESG risk-related disclosures contained in the draft ITS. However, there is some uncertainty as to how the final version of the Omnibus Package will look once agreed by the co-legislators and as such the EBA will only be in a position to finalise the draft ITS once there is certainty.

Opinion

In the Opinion the EBA makes certain recommendations to the Commission and Member State competent authorities. It provides that for the period starting from the reference date of 30 June 2025 until the draft ITS are adopted and enter into force to not prioritise the enforcement of the:

  • Disclosure of certain ESG disclosure templates (notably EU 6 to EU 10, and specific columns in Templates 1 and 4) of the Commission’s Implementing Regulation (EU) 2024/3172, for large institutions with listed securities.
  • Collection of templates EU 6 to 10, and specific columns in Templates 1 and 4 of the EBA Decision EBA/DC/498 of 6 July 2023, for large institutions with listed securities.
  • Disclosure of the corresponding ESG templates under the Commission’s Implementing Regulation (EU) 2024/3172 for all other institutions recently brought under the scope of Article 449a of the CRR.

Dashboard

The EBA has also published an updated version of its ESG risk dashboard. The ESG risk landscape across EU/EEA banks appears stable, thus reflecting the long-term horizon of climate-related risks and the gradual pace of change in banking portfolios.