EBA publishes final amending POG guidelines for ESG retail banking products

The European Banking Authority (EBA) has published its final amending product oversight and governance (POG) guidelines for retail banking products, having consulted on them in July 2025. The guidelines make targeted amendments clarifying how firms should address environmental, social and governance (ESG) considerations and greenwashing risks throughout the product lifecycle. The EBA considers the update necessary in light of its June 2024 greenwashing report, which identified growing risks across the financial sector, and to align with recent amendments to the Capital Requirements Directive (CRD) and Capital Requirements Regulation (CRR) on ESG risk management.

Following feedback, the EBA clarifies various provisions and adjusts some of the wording proposed in the consultation, making ESG and greenwashing considerations more explicit within the current requirements where products are offered and sold to consumers. The guidelines adjust only a limited number of existing requirements, relating to the subject matter, the manufacturer's internal control functions, the target market, distribution channels, information for distributors, and information and support for the manufacturer's arrangements.

The EBA also makes consequential updates to reflect wider regulatory developments, including revisions to its Founding Regulation, the internal governance guidelines under the CRD and the sound management of third-party risk regarding non-information communication technology services.

The guidelines are expected to be published in all EU official languages this year and will apply from 11 January 2027. Competent authorities must report whether they comply with the guidelines within two months of the publication of the translations.

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