The. Today’s proposal aims to enhance transparency and consistency of disclosures in a proportionate manner. The consultation runs until 22 August 2025.

This consultation paper finalises the implementation of the Pillar 3 disclosure requirements introduced by the banking package (CRR3), including the extension of the scope of application of ESG risks-related disclosures to all institutions and the disclosure of information on shadow banking and equity exposures.

In line with the European Commission’s omnibus proposal  to reduce reporting costs and simplify sustainability reporting, the EBA has designed a proportionate approach for ESG disclosures based on the institution’s type, size and complexity, with simplified disclosures for banks other than large, particularly for those that are small or non-listed.

Furthermore, the consultation does not introduce any new requirement on banks already disclosing ESG related information (large listed banks),  but aims to simplify the reporting process by clarifying the existing requirements based on the experience gained. It does this by introducing materiality considerations regarding the frequency of some of the disclosures and by ensuring full and permanent alignment with the Taxonomy Regulation in terms of scope and definition of the Green Asset Ratio (GAR) templates.

Transitional provisions have been introduced to support institutions and facilitate the initial implementation of the new requirements. For ESG disclosures, in particular, consistently with these transitional provisions, in order to clarify expectations, ensure consistency and reduce operational burden, for the period until the ITS now being consulted starts applying, the EBA is encouraging supervisory flexibility. For this purpose, the EBA is considering issuing a no action letter advising competent authorities not to prioritise the enforcement of the disclosure of certain templates related to the Green Asset Ratio and Taxonomy Regulation for large and listed institutions; nor the enforcement of the disclosure of any ESG-related templates for other institutions.

Finally, the EBA is further supporting institutions in their compliance with disclosure requirements by providing an updated mapping tool between Pillar 3 and supervisory reporting.

Responses to the consultation can be sent to the EBA by clicking on the "Submit response" button on the consultation page.

All contributions received will be published after the consultation closes, unless requested otherwise. The deadline for the submission of comments is 22 August 2025

A public hearing on this consultation will take place via conference call on 26 June 2025 from 11:00 to 12:30 CEST. Deadline for registration is 24 June 2025 at 16:00 CEST.

Regulation (EU) 2024/1623 of the European Parliament and of the Council amending Regulation (EU) No 575/2013 (CRR3) implements the Basel Committee on Banking Supervision (BCBS)’s December 2017 Basel III post-crisis regulatory reforms in EU, while considering the specific aspects of the EU's banking sector. The new banking package envisages further harmonisation of supervisory powers and enforcement tools and an increase in transparency and proportionality in the Pillar 3 disclosure requirements.

The EBA’s plan on how to implement the mandates included in the Banking Package is explained in the 'EBA Roadmap on strengthening the prudential framework', published in December 2023. Commission Implementing Regulation (EU) 2024/3172 including the new and amended disclosure requirements directly linked to Basel III implementation was published last year as part of step 1 of the EBA roadmap. As part of step 2 of the EBA roadmap, the Pillar 3 disclosure framework is amended to consider the other CRR 3 amendments to Part Eight of the CRR, including disclosure requirements on equity exposures (Article 438(e) of CRR3); new disclosure requirements on the aggregate exposure to shadow banking entities (Article 449b of CRR3); and the extension of the scope of application of disclosure requirements on ESG risks to all institutions (Article 449a of CRR3).

In addition, the Guidelines on disclosure of non-performing and forborne exposures (EBA/GL/2018/10 as amended by EBA/GL/2022/13) are repealed, considering the extension of the disclosure requirements on non-performing exposures and forbearance to listed SNCI and other non-listed institutions in accordance with the CRR 3 Articles 433b and 433c.

On February 26, 2025, the Commission published the Omnibus proposal aimed at simplifying sustainability reporting under the Corporate Sustainability Reporting Directive (CSRD), Corporate Sustainability Due Diligence Directive (CSDDD), and Taxonomy Regulation.