EBA issues no-action letter on the application of the ESG Pillar 3 disclosure requirements

The European Banking Authority (EBA) has issued an Opinion in the form of a no-action letter dated 5 August, addressing the application of ESG Pillar 3 disclosure requirements under the EBA disclosure implementing technical standards (ITS). The letter includes recommendations to national competent authorities aimed at easing the implementation timeline for revised ESG Pillar 3 disclosure requirements under the Capital Requirements Regulation (CRR). The objective is to alleviate operational burdens on institutions pending the adoption and publication of amendments to Commission Implementing Regulation (EU) 2024/3172 in the Official Journal of the European Union.

Specifically, the EBA advises national competent authorities not to prioritise enforcement for the following: (i) the disclosure of certain ESG disclosure templates (specifically EU 6 to EU 10 and parts of Templates 1 and 4) for large institutions with listed securities, as required under Commission's Implementing Regulation (EU) 2024/3172; (ii) the collection of the same templates and columns as referenced above, under the EBA Decision EBA/DC/498 of 6 July 2023 for large institutions and securities; and (iii) the disclosure of corresponding ESG templates under Commission's Implementing Regulation (EU) 2024/3172 for institutions that have only recently come under the scope of Article 449a of the CRR. Alongside the no-action letter, the EBA has also published an updated version of the ESG risk dashboard. The dashboard indicates that the ESG risk landscape across EU/EEA banks remains stable. The EBA notes that future editions of the dashboard will be adjusted in line with the no-action letter and the recommendations outlined therein.

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