Publication date: 31 January 2019

The EBF answers to the Technical Expert Group (TEG) questionnaire on their report on climate-related disclosures. 

The EBF sees the TEG Report as a key step in the much-needed transition to a low-carbon economy.

We welcome the revision of the non-binding guidelines of the Non-Financial Reporting Directive (NFRD) to provide further guidance on how to disclose climate-related information, and we are satisfied with the level of alignment between the NFRD and the TCFD frameworks.

We warn of unwanted effects of the proposal, that we clarify along our answers, with a specific focus on the need to ensure that parallel reporting processes are not in place – not to distort the reporting happening already under Pillar 3. 

Taking a deep look into sector specific guidance for banks, our recommendations are clear. We are wary of disclosures that could pose risks of creating a sustainability bubble, or hamper the correct functioning of risk-disclosure and risk-management processes by banks. 

EBF members are looking into different innovative ways to bridge the currently existing gaps that Scope 3 GHG emissions pose. Lack of data is palpable, and alternative solutions should be considered to report about climate impacts through banking activities.