The European Banking Authority (EBA) has launched a public consultation on proposed amendments to disclosure requirements under the Capital Requirements Regulation (CRR3), aiming to reduce reporting complexity and align sustainability obligations with the European Commission’s broader goal to simplify ESG reporting.
The proposals focus on a more proportionate disclosure regime covering ESG-related risks, equity exposures, and aggregate exposure to shadow banking entities.
The EBA is pushing for a differentiated approach to ESG disclosures that takes into account the size, type, and complexity of institutions. Under this plan, large listed banks will not face new obligations, but smaller and non-listed banks will benefit from simplified requirements. These amendments reflect the Commission’s recent efforts, including the Omnibus proposal, to reduce the compliance burden on financial institutions while promoting transparency and consistency.
As part of this effort, transitional arrangements and supervisory flexibility will be offered to institutions during the implementation period. The EBA is also encouraging national regulators to apply a pragmatic approach, suggesting they deprioritise enforcement of certain ESG disclosure templates—particularly those relating to the Green Asset Ratio (GAR) and Taxonomy Regulation—for both large listed and other institutions.
The proposed changes represent the final step in implementing the Pillar 3 disclosure requirements introduced by CRR3. These changes expand ESG disclosure obligations to all institutions, introduce specific reporting on shadow banking exposures, and update the framework to reflect new NACE codes used for economic activity classification across the EU.
To help with implementation, the EBA will provide a revised mapping tool linking Pillar 3 disclosures with supervisory reporting.
The consultation is open until 22 August 2025, with stakeholders encouraged to provide feedback via the EBA’s online portal. A public hearing will be held virtually on 26 June 2025, with registration closing on 24 June.
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