EBF response to the EBA CP on ESG Pillar 3 Disclosure under CRR

The European Banking Federation (EBF) welcomes the opportunity to respond to the EBA’s public consultation on proposed amendments to the European Commission’s Implementing Regulation on Pillar 3 disclosures under the CRR3. We also welcome the EBA issuing a no-action letter on 6 August 2025 according to which Competent Authorities should not prioritize the enforcement of the disclosure of the ESG risk templates until the amended ITS is finalized, and the clarity that the EBA will wait until the Omnibus Package is finalized before finalizing this ITS. We encourage the EBA to use the time provided by this Opinion to consider more extensive amendments to the ITS to address the above concerns and those detailed throughout this letter.

The following key points highlight our response to the consultation:

Advocacy for reduced frequency and proportionality: We strongly recommend shifting to annual disclosure frequency for all ESG Pillar 3 templates, including for large institutions, to align with Basel Committee P3 voluntary standards requirements, reduce operational burden, and reflect the annual availability of underlying data (e.g., EUT KPIs and emissions). Semi-annual reporting provides limited additional value and should be avoided, particularly for non-listed large institutions and subsidiaries.

Alignment with CSRD and avoidance of duplications: ESG disclosures should harmonize with CSRD scope and requirements to minimize redundancy; we propose cross-referencing to annual reports for qualitative information. We welcome the suspension of GAR and Taxonomy disclosures until end-2026 but urge full deletion of Taxonomy-related data (e.g., GAR/BTAR in Templates 6-10) from Pillar 3 to prevent misalignment and unnecessary burdens, emphasizing that these are sustainability metrics, not prudential risks.

Materiality-based approach: A consistent materiality framework, as per EBA ESG risk management guidelines, should apply across all disclosures to ensure only relevant information is reported, reducing burden while enhancing usefulness. This includes conditional omissions for immaterial risks and flexible responses in qualitative tables (e.g., Tables 1-3).

Transitional provisions and implementation timeline: In case Taxonomy-related disclosures are not removed from the Pillar 3 per above, we propose extending the suspension to end-2027 to match the Taxonomy Delegated Act review. Suggest clarifying that transitional relief covers all related columns (e.g., in Templates 1 and 4) and can be applied immediately. Align ITS entry dates with ESG Risk Guidelines (from January 2027) for SNCIs.

Simplification of templates and sector classifications: Suggest removing or simplifying specific templates (e.g., Template 3 on alignment metrics, Template 4 on top carbon emitters) due to limited prudential relevance and data challenges. For sector breakdowns, exclude non-contributory activities (e.g., wholesale/retail fuel sales), ensure consistency across templates, and allow voluntary or aggregated reporting to address confidentiality and comparability issues.

Data quality and methodology clarifications: Highlight challenges with proxies/estimates (e.g., align with PCAF standards), EPC labels (avoid mandatory estimates), and financed emissions (duplicative with CSRD; clarify calculation methods). Propose flexible scenarios (e.g., beyond IEA NZE) and definitions (e.g., for transition finance, pure-play companies) to improve comparability and feasibility.

Overall support for proportionality with practical adjustments: We endorse the tiered disclosure sets based on institution size and listing status but urge consistency at group level for subsidiaries. Recommend naming conventions aligned with other Pillar 3 templates, fast communication channels for errors, and confirmation on scopes (e.g., exemptions for non-listed SNCIs in certain templates) to enhance clarity and efficiency.

You can access the full EBF response here.