6 August 2025
The European Banking Authority (EBA) today published a no-action letter on the application of the ESG Pillar 3 disclosure requirements under the EBA disclosure Implementing Technical Standards (ITS). This no-action letter aims to address legal and operational uncertainties linked to the evolving ESG disclosure framework, in light of the proposed amendments under the European Commission’s Omnibus legislative package on sustainability reporting. The EBA is also updating its ESG risk dashboard.
This no-action letter formalises the guidance already provided in the EBA’s Consultation Paper published in May 2025 on the amending ITS of the EBA Pillar 3 disclosure framework. In particular, it includes the following recommendations to competent authorities until the EBA amending ITS included in the Consultation Paper enter into force:
To not prioritise the enforcement of the disclosure of certain ESG disclosure templates (notably EU 6 to EU 10, and specific columns in Templates 1 and 4) of the Commission’s Implementing Regulation (EU) 2024/3172, for large institutions with listed securities;
To not prioritise the enforcement of the collection of templates EU 6 to 10, and specific columns in Templates 1 and 4 of the EBA Decision EBA/DC/498 of 6 July 2023, for large institutions with listed securities;
To not prioritise the enforcement of the disclosure of the corresponding ESG templates under the Commission’s Implementing Regulation (EU) 2024/3172 for all other institutions recently brought under the scope of Article 449a of the Capital Requirements Regulation (CRR).
The EBA remains committed to delivering a coherent and streamlined ESG disclosure framework and will continue to work closely with EU institutions and stakeholders to ensure smooth implementation of the new requirements.
The EBA is also publishing today an updated version of the EBA ESG risk dashboard. The ESG risk landscape across EU/EEA banks appears stable, thus reflecting the long-term horizon of climate-related risks and the gradual pace of change in banking portfolios.
It should be noted that the content of the ESG risk dashboard will be adjusted in the next editions in line with the no-action letter, and the recommendations to authorities not to prioritise the enforcement of the disclosure of those specific templates and information.
Legal basis and background
The non-action letter has been drafted in accordance with Article 9c of Regulation (EU) No 1093/2010[1] (EBA founding Regulation), which gives the EBA the power to issue no-action letters, if it considers that the application of one of the relevant legislative acts is liable to raise significant issues. This is the case when provisions contained in such act may directly conflict with another relevant act, and if based on some relevant information, the EBA considers that the application of the relevant provisions raises significant exceptional issues in terms of market confidence, customer or investor protection, the orderly functioning and integrity of financial markets or commodity markets, or the stability of the whole or part of the financial system in the Union.
Article 434a of the CRR mandates the EBA to develop ITS to specify uniform disclosure formats and accompanying IT solutions.
Article 449a of the CRR, as introduced by Regulation (EU) 2019/876 (CRR2), required large institutions with securities admitted to trading on a regulated market in a Member State to disclose their exposures to ESG risks. These requirements were further operationalised through the Commission’s Implementing Regulation (EU) 2024/3172, which sets out detailed ITS for ESG disclosures.
Regulation (EU) 2024/1624 (CRR3) amended Article 449a, expanding the scope of ESG disclosures to all institutions. These revised obligations apply from 1 January 2025.
[1] Regulation (EU) No 1093/2010 of the European Parliament and of the Council of 24 November 2010 establishing a European Supervisory Authority (European Banking Authority) amending Decision No 716/2009/EC and repealing Commission Decision 2009/78/EC (OJ L 331, 15.12.2010, p. 12).
Documents
Opinion on the application of the provisions relating to disclosures on ESG risks
Letter to Mr Berrigan re the No action letter on the application of the ESG P3 disclosures
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Press contacts
Franca Rosa Congiu, press@eba.europa.eu +33 1 86 52 7052