On 22 May 2025, the European Banking Authority (EBA) issued a consultation paper on draft implementing technical standards (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.
Specifically, the consultation paper covers:
- Revised disclosure requirements on ESG related risks as per Article 449a of the CRR 3 including the extension of its scope of application to small and non-complex institutions (listed/non-listed), other institutions (listed/non-listed), large non-listed institutions and large subsidiaries.
- The new disclosure requirements on the aggregate exposure to shadow banking entities as of Article 449b of the CRR 3.
- The amended disclosure requirements on equity exposures of Article 438(e) of the CRR 3.
- The amended disclosure requirements on credit quality loans and advances to non-financial corporations by industry, to reflect the new NACE classification code for economic activities set out in Commission Delegated Regulation (EU) 2023/137.
The EBA also proposes to clarify that guidelines EBA/GL/2018/10 as amended by EBA/GL/2022/13 have been replaced and therefore repealed since the related disclosure requirements are already included in Commission Implementing Regulation (EU) 2024/3172 repealing Commission Implementing Regulation (EU) 2021/637.
Next steps
The deadline for comments on the consultation paper is 22 August 2025.
The ITS are expected to be finalised and submitted to the Commission during Q4 2025.