EBA is seeking to develop uniform reporting formats, frequencies, and instructions to ease the reporting burden on EU banks.
By Betty M. Huber, Axel Schiemann, Anne Mainwaring, and Charlotte Collins
Key Points:
- Ad hoc reporting of ESG risks by large EU banks is being replaced with a tiered framework applicable to all institutions within scope of the CRR.
- Three sets of templates are proposed, which are calibrated by reference to the size, complexity, and listing status of the reporting institution.
- Implementation is targeted for September 2027; stakeholders have until 10 July 2026 to respond.
The European Banking Authority (EBA) has announced a collection of measures to simplify EU supervisory reporting, including in relation to ESG matters. Amongst other initiatives, the EBA is proposing to amend the Implementing Technical Standards (ITS) on supervisory reporting (Commission Implementing Regulation (EU) 2024/3117) in order to reduce the reporting burden for EU banks as part of wider efforts to simplify and streamline regulatory requirements.
The proposals include a dedicated module on ESG reporting, establishing new, uniform templates and instructions for the supervisory reporting of ESG risks by EU banks. The EBA stresses that, in developing the proposals, particular attention has been paid to streamlining templates, consolidating data points, removing duplicative or low-use information, and embedding proportionality mechanisms.
Background
The proposals arise from the EBA’s mandate under Article 430(7) of the Capital Requirements Regulation (CRR), as amended by CRR3, which requires the EBA to develop uniform reporting formats, frequencies, and instructions to enable national regulators to monitor EU banks’ compliance with prudential obligations relating to ESG risks. The framework builds on the EBA’s broader ESG roadmap, including its supervisory guidelines on the management of ESG risks and its previous work on Pillar 3 ESG disclosures. It also builds on the final draft ITS on disclosures developed pursuant to Article 449a of the CRR, which are expected to be published in the coming weeks.
To date, the EBA has collected ESG data on an ad hoc basis under EBA Decision EBA/DC/498, which applies to large institutions with securities admitted to trading on a regulated market. The new framework will replace the ad hoc collection and extend ESG supervisory reporting obligations to all institutions within the scope of the CRR, including small and non-complex institutions (SNCIs), although with an overlay of proportionality. The EBA also intends that its proposals will lead to maximum harmonisation of the supervisory reporting framework by allowing national regulators to remove any parallel data collections on the same topics.
Key Proposals
One of the most significant features of the proposals is the introduction of a tiered, proportionate approach to reporting. Three sets of templates are proposed, which are calibrated by reference to the size, complexity, and listing status of the reporting institution:
- Large institutions (both listed and non-listed) will be subject to a comprehensive set of seven templates, largely aligned with the Pillar 3 ESG disclosure framework but including two new supervisory-specific templates covering environment-related concentration risk and exposures to environmental risks beyond climate.
- Other listed institutions and large subsidiaries will report against a simplified set of six templates, including a streamlined version of the physical risk template.
- SNCIs and other non-listed institutions will report against a single, reduced template capturing an aggregated view of transition and physical risks.
The proposed reporting framework is summarised in the table below:
| Template | Large institutions | Other listed institutions and large subsidiaries | SNCIs and other non-listed institutions | Materiality thresholds |
|---|---|---|---|---|
| D 01.00: Climate Change transition risk: Credit quality of exposures by sector, emissions, and residual maturity | Semi-annual (for large institutions with total assets of €30 billion or above) | – | – | Country breakdown applying FINREP materiality thresholds and thresholds at sectoral level |
| D 01.02: Climate Change transition risk: Credit quality of exposures by sector, emissions, and residual maturity (subset of D 01.00) | Semi-annual (for large institutions with total assets below €30 billion) | Annual | ||
| D 01.01 Template 1A: Transition and physical risk | – | – | Annual | |
| D 02.00: Climate change transition risk: Loans collateralised by immovable property – Energy performance of the collateral | Semi-annual | Annual | – | |
| D 03.00: Indicators of potential climate change transition risk: emission intensity per physical output and by sector | Annual | – | – | |
| D 04.00: Environment-related concentration risk (NEW) | Semi-annual | Annual | – | Report counterparties for which the total exposure level exceeds €10 million |
| D 05 00: Climate change physical risk: Exposures subject to physical risk | Semi-annual | – | – | Country breakdown applying FINREP materiality thresholds |
| D 05.01: Climate change physical risk: Exposures subject to physical risk | – | Annual | – | |
| D 10.00: Mitigating actions: Exposures contributing to sustainability objectives | Annual | Annual | – | |
| D 11.00: Banking book- Exposures to environmental risks (beyond climate) – Physical and transition risks (NEW) | Annual | Annual | – | Country breakdown applying FINREP materiality thresholds |
The EBA has sought to streamline the framework by removing several templates previously included in the ad hoc collection, including templates on information under the Taxonomy Regulation (templates relating to the Green Asset Ratio and the Banking Taxonomy Alignment Ratio) and the template on exposures to the top 20 carbon-intensive firms. The removal of these templates reflects the pivot away from Taxonomy-related disclosures.
Next Steps
Comments on the proposals are requested by 10 July 2026. The EBA held a public hearing on the consultation in early May, and plans to hold a workshop on efficient reporting in June. The proposed changes would apply from September 2027.
