The European Banking Authority (EBA) has issued a no-action letter to clarify the application of the ESG Pillar 3 disclosure requirements under its disclosure Implementing Technical Standards (ITS).
The move addresses legal and operational uncertainties arising from the evolving ESG reporting framework, particularly in light of proposed changes in the European Commission’s Omnibus legislative package on sustainability reporting.
This no-action letter builds on the guidance set out in the EBA’s Consultation Paper from May 2025, which proposed amendments to the ITS for ESG Pillar 3 disclosures. The EBA has recommended that competent authorities temporarily deprioritise enforcement in several key areas until the amending ITS takes effect. This includes not prioritising enforcement of the disclosure of ESG templates EU 6 to EU 10, as well as certain columns in Templates 1 and 4 of the Commission’s Implementing Regulation (EU) 2024/3172, for large institutions with listed securities.
Similarly, the EBA has advised against prioritising the enforcement of collecting these templates and data columns under EBA Decision EBA/DC/498 of 6 July 2023 for the same institutions. The guidance also extends to other institutions that have only recently come under the scope of Article 449a of the Capital Requirements Regulation (CRR), recommending no prioritisation of enforcement for the corresponding ESG templates.
According to the EBA, these measures are intended to ease operational pressures on institutions while maintaining the momentum towards a “coherent and streamlined ESG disclosure framework”. The authority said it will continue collaborating with EU institutions and stakeholders to ensure the smooth rollout of the updated requirements.
In parallel, the EBA has released an updated ESG risk dashboard incorporating data up to December 2024. The results suggest the ESG risk profile of EU/EEA banks has remained stable, reflecting the long-term nature of climate-related risks and the gradual shifts in banking portfolios. The authority noted that the content of future ESG risk dashboards will be adjusted to align with the recommendations outlined in the no-action letter.
The EBA emphasised that these changes aim to provide clarity and predictability for institutions during the transition period, helping them prepare for the full implementation of the amended ESG disclosure framework.
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