The European Banking Authority (EBA) has published final draft Implementing Technical Standards (ITS) that overhaul how banks must disclose information on ESG risks, as well as introducing new requirements covering equity and shadow banking exposures.
The updated standards finalise the disclosure requirements introduced under the Capital Requirements Regulation (CRR 3), completing a significant regulatory milestone for European financial institutions. The revisions are designed to bring the Pillar 3 disclosure framework into closer alignment with the European Sustainability Reporting Standards (ESRS) under the Corporate Sustainability Reporting Directive (CSRD), reducing duplication by allowing institutions to cross-refer to Pillar 3 disclosures within their broader sustainability reporting.
A key feature of the revised ITS is a tiered “core plus supplement” model, calibrated according to an institution’s size and operational complexity. Under the new structure, large institutions will be required to report 37% fewer datapoints than under the current regime, while medium-sized institutions will see a 17% reduction. Small and Non-Complex Institutions (SNCIs) stand to benefit most substantially, with an 84% reduction in datapoints compared to those currently required of large institutions. Taxonomy-related disclosures will also be discontinued. The EBA has additionally committed to centrally pre-filling and publishing ESG data in its Pillar 3 Data Hub on behalf of SNCIs, drawing on supervisory reporting to reduce the administrative burden on smaller firms.
The ITS extend ESG disclosure obligations beyond large institutions for the first time, bringing all institutions within scope on a proportionate basis as mandated by CRR 3. For large institutions, the framework builds on existing requirements while streamlining them in line with the EU’s broader simplification agenda and the Omnibus package. The revisions also incorporate recommendations from the Joint Bank Reporting Committee (JBRC) on semantic integration to support more coherent, joined-up reporting across frameworks.
Stakeholders are encouraged to review the final draft ITS alongside the EBA’s related consultation paper on ESG supervisory reporting, as the two documents are closely linked and together provide a comprehensive picture of the overall ESG framework.
The EBA will now submit the final draft ITS to the European Commission for adoption. Work is also underway to develop a Data Point Model (DPM) and XBRL taxonomy to facilitate submission to the Pillar 3 Data Hub, alongside an updated mapping tool expected to be published in 2026, connecting Pillar 3 disclosures to supervisory reporting. The standards are expected to apply from 31 December 2026, with SNCIs subject to the requirements from 31 December 2027, subject to any further adjustments arising from the European Commission’s ongoing work.
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