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Response to the European Banking Authority
On 22 May 2025, the European Banking Authority (EBA) launched a consultation in relation to amended disclosure requirements for ESG risks, equity exposures and aggregate exposure to shadow banking entities within the framework of the European Commission’s Implementing Regulation on Pillar 3 disclosures under the CRR3.
This note presents our key positions and recommendations on the following aspects of the Pillar 3 disclosure framework:
On the scope of institutions, proportionality and simplification measures
- The overall simplification is welcome, particularly the reduced reporting frequency and a proportionate, gradual approach for listed subsidiaries, SNCI and non-listed institutions.
On transitional provisions introduced in the ITS and interim guidance until the finalisation of the ITS
- We strongly disagree with the suspension of GAR reporting for 2025 and 2026. While we acknowledge the significant methodological challenges in calculating the GAR, suspending reporting would create a gap in transparency and accountability regarding European banks’ contribution to financing green activities.
Suspending it would set a precedent that risks undermining the future of taxonomy-based ratios at the banking level—similar to recent delays in CSRD and CSDDD, which raise concerns about potential rollbacks.
On review of the quantitative information on ESG
- Enhance fossil exposure reporting by aligning with the CPRS classification, introduce more granularity for agriculture, and include including both stock and flow data.
- Ensure greater ambition in Template 3 regarding the list of covered sectors, the NACE codes involved and interoperability with the NZBA framework
- Include additional forward-looking indicators (e.g. technology mix, volume trajectory) beyond financed emissions, which are currently insufficient on their own.
- Establish a single reference list for identifying exposures to top emitting firms to ensure consistency across institutions.
- Avoid over-complexity in Template 5: replace NUTS 3 regional granularity with a more feasible breakdown by country, Europe, and Rest of World.
