EBA publishes draft amendment to ESG disclosure requirements – the principle of proportionality takes hold

The EBA specifies the new requirements for ESG disclosure in accordance with CRR

The draft ITS EBA/CP/2025/07 published on 22 May 2025 details the new requirements for ESG disclosure in accordance with CRR, Article 449a and supplements the disclosure requirements set out in Regulation (EU) 2024/3172.

The draft applies the ESG-related disclosure requirements to all CRR institutions and revises or extends the existing ESG disclosure requirements, in some cases significantly. The draft relates to:

• large, non-listed institutions,
• other institutions,
• large subsidiaries and
• small and non-complex institutions (SNCIs).

With this draft, the EBA takes into account the principle of proportionality. This means that the size, scope and complexity of an institution’s business are decisive for the ESG data to be disclosed.

• Large, listed and non-listed institutions: analogous to the current ESG disclosure, all templates, but with various adjustments/extensions.
• Other listed institutions and large subsidiaries: simplified ESG disclosure, i.e. not the full scope.
• Small and non-complex institutions (SNCI) and other non-listed institutions: minimal disclosure with only the most material information.

The reporting obligations for each size of institution are shown below.

The current ten templates to be disclosed have been extensively revised in the draft ITS. In addition to content adjustments and new templates, rows and columns have also been added. The main changes are listed below:

• NACE sector classification according to NACE Rev. 2.1 (templates 1 and 5),
• expansion of template 2 to include the separate disclosure of covered bonds and estimated EP score values,
• fundamental revision of template 3 with regard to the metrics and the NACE sectors; new, differentiated disclosure of the metrics with regard to base year, reporting year and targets,
• new, more differentiated consideration of specific events for physical risks in template 5 (temperature-related, wind-related, water-related, caused by solid substances); The differentiation between acute and chronic events no longer applies
• Adoption of the GAR calculation from the Taxonomy Regulation for templates 7 and 8 (no separate GAR calculation as part of the ESG disclosure)
• Simplification of the presentation and extension to all six environmental objectives in template 9 and
• complete revision of template 10 with a focus on risk-mitigating measures outside the EU taxonomy in relation to all six environmental objectives.

Other listed institutions and large subsidiaries must familiarize themselves with the new Template 5A. Template 5A is a shortened version of Template 5, has a reduced number of maturity buckets and does not include stage 2 exposures or specific events for physical risks.

Small and non-complex institutions must deal with Template 1A and disclose data on transition risk and physical risk. These must be broken down by economic sector (NACE classification) and geographical location (NUTS code) of the counterparty’s activity/collateral exposed to climate change and by residual maturity.

Article 433a CRR stipulates that large, listed institutions must disclose ESG risks every six months. In this regard, the EBA is now proposing in this draft ITS that greater consideration be given to proportionality for large institutions.

The disclosure of some tables and templates could be reduced to annually for reasons of materiality, for example, if more frequent disclosure of this data cannot be justified. For example, it should be sufficient to disclose

• the qualitative information in Tables 1, 1A, 2 and 3,
• the data for Template 3 (Indicators of potential climate change transition risk: emission intensity per physical output and by sector) and
• the data on mitigating actions in Templates 6-10

only on an annual basis.

Transitional provisions are also provided for large, listed institutions. During the period until the end of 2026, they will continue to fulfill the disclosure requirements in accordance with the current requirements of Regulation (EU) 2024/3172. However, they may make use of an exemption in accordance with the draft ITS.

For templates that are aligned with the Green Asset Ratio (GAR) and the Taxonomy Regulation (templates 6 to 10), it is envisaged that they will be exempt from the disclosure requirement until the end of 2026.

December 31, 2026 is envisaged as the first disclosure deadline in accordance with the requirements of the Draft ITS. This means that institutions have more than a year to adapt their current implementation and align it with the new requirements of the EBA draft. However, the supervisors still need until the end of 2025 to finalize the draft.