On 5 August 2025, the EBA published a statement on the ESG disclosure requirements under Article 449a CRR. The background is the extension of this requirement to all institutions through the so-called CRR 3. At the same time, uncertainties remain regarding the final design, as the legislator is still revising key aspects of the Taxonomy Regulation and the application of sustainability reporting (Corporate Sustainability Reporting Directive, CSRD) as part of the “Omnibus” package (see TSI kompakt of 26 February).
During this transitional phase, the EBA recommends that supervisory authorities temporarily do not prioritise the enforcement of certain ESG requirements. This provides provisional legal certainty. In parallel, the EBA updated its ESG dashboard with data as of December 2024.
Recommended steps for supervisory authorities
- The new requirements apply from 1 January 2025, with the first disclosure due as of 31 December 2025.
- Authorities should, for large institutions, temporarily refrain from enforcing certain ESG templates (EU 6–10, Template 1c, Template 4c).
- For all other institutions, authorities should generally not prioritise enforcement of the corresponding ESG disclosure templates.
- Use the dashboard: The updated EBA data shows physical risks and low shares of green assets.
Outlook: New requirements in preparation
The EBA plans to finalise the revised technical standards for ESG disclosure after completion of the legislative procedures for the Omnibus package. A consultation on the integration of ESG risks into the SREP is underway. The final update of the disclosure standards is expected to enter into force in early 2026.