EBF RESPONSE

EBF Responds to the Commission’s Consultation on Revised Sustainability Reporting Standards

Brussels, 4 June 2026 – The European Banking Federation (EBF) has submitted its response to the Commission’s consultation on revised sustainability reporting standards, both the ESRS and the voluntary standards, focusing solely on the changes proposed by the European Commission compared with EFRAG’s version.

The EBF believes that EFRAG’s proposed standards represent an acceptable compromise, and a regulatory pause is necessary to allow for implementation assessment and the identification of lessons for a potential post-implementation review. Therefore, only a limited number of further clarifications are necessary:

• Clarify how the value chain cap is applied in practice, including that it applies solely to CSRD reporting, how it applies to conditional datapoints, and what the differences are for smaller companies.
• Specify that sanctions and fines are reportable only following a final, non-appealable decision.
• Clarify the level of evidence required to substantiate non-materiality conclusions, particularly in complex group structures, to avoid the risk of disproportionate audit expectations regarding proof of non-materiality.
• Ensure flexibility in data sourcing, particularly where counterparty-level information is not available.

For more information:

Denisa Avermaete, Head of Sustainable Finance Team,d.avermaete@ebf.eu

Jānis Priekulis, Senior Policy Adviser – Sustainable Finance, j.priekulis@ebf.eu

The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The federation is committed to a thriving European economy that is underpinned by a stable, secure, and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.