Response to consultation on Implementing Technical Standards on amended disclosure requirements for ESG risks, equity exposures and aggregate exposure to shadow banking entities
1. Do you have any comments on the proposed set of information for Large institutions?
(i) Key position
We support the simplified approach that require “other listed institutions”, “large subsidiaries” and “SNCI and other non-listed institutions” to report on their ESG risks, through a tailored approach with proportionate reporting obligations. We also confirm the relevance of aligning the GAR requirements with the taxonomy regulation scope.
(ii) Supporting Evidence and Rationale
Aligning the GAR with the Taxonomy Regulation scope ensures regulatory consistency. However, we note that ongoing discussions on simplifying the Taxonomy Regulation tend to focus on reducing the number of entities subject to the regulation. In our view, a more effective simplification would be to reduce the complexity of the reporting, rather than limiting its scope—thus retaining wide data coverage[1] without increasing the compliance burden.
[1] See our note on the UE Taxonomy providing recommendations to simplify and optimize the regulation: Optimizing the UE Taxonomy to make it a real economic steering tool for the transition
2. Do you have any comments on the simplified set of information for Other listed institutions and Large subsidiaries?
We confirm the relevance of the simplified set of information for Other listed institutions and Large subsidiaries.
3. Do you have any comments on the simplified set of information proposed for SNCI and other non-listed institutions?
We also welcome the initiative to introduce a simplified and essential set of disclosure requirements for SNCIs and other non-listed institutions.
4. Do you have any comments on the proposed approach based on materiality principle to reduce the frequency (from semi-annual to annual) of specific templates (qualitative, template 3, and templates 6-10) for large listed institutions?
(i) Key position
We support the proposed approach, notably the annual frequency of taxonomy ratios (templates 6 to 9) and carbon intensity reduction metrics and targets (template 3). We also recommend that any omissions based on the materiality principle be clearly justified and reasonably explained.
(ii) Supporting Evidence and Rationale
The proposed annual reporting frequency is a proportionate and effective way to reduce compliance burden while preserving the robustness and accuracy of the required information. Nevertheless, regarding the application of the materiality principle, we would like to highlight that its implementation is not always clearly defined across other parts of the disclosure framework, which may result in the omission of relevant information.
5. Do you have any comments on the transitional provisions and on the overall content of section 3.5 of the consultation paper?
(i) Key position
We do not support the proposal to suspend all GAR reporting until end of 2026. Large institutions should continue to disclose their Green Asset Ratios based on the current regulatory framework and methodological approach.
(ii) Supporting Evidence and Rationale
While we acknowledge the need for improved alignment between ESG Pillar 3 and the Taxonomy Regulation, and the significant methodological challenges in calculating the GAR, suspending reporting for 2025 and 2026 would create a gap in transparency and accountability regarding European banks’ contribution to financing green activities. Such a gap would hinder effective monitoring of the European banking sector and therefore deprive policy makers and public opinion of valuable information their decision-making processes rely on. Anticipated future changes to the GAR methodology or its alignment with the Taxonomy does not justify a complete interruption of disclosure for the years 2025 and 2026. Moreover, banks have already made substantial investments to comply with the existing GAR requirements, and maintaining current reporting obligations would not represent a significant additional compliance burden.
6. Do you have any comments on the proposed amendments to Table 1 and Table 3?
Through our analysis, we observed that many of the qualitative sections in banks’ Pillar 3 reports were largely replicated from language already present in CSRD disclosures. Based on this observation, we developed a table showing the correspondence between Tables 1, 2 and 3 of ESG Pillar 3 and relevant disclosure requirements under CSRD and ESRS, with the aim of proposing cross-references that could help reduce the reporting burden for banks. We therefore agree with the proposal of paragraph 32 to incorporate reference Pillar 3 ESG qualitative tables in the sustainability statement.
7. Do you have any further suggestions on Table 1A?
No comment
8. Do you have any comments on the proposed additions and deletions to the sector breakdown?
We agree with the removal of Category I – Accommodation and Food Services Activities – from the list of sectors highly contributing to climate change since it is not included in the relevant sections defined in Commission Delegated Regulation (EU) 2020/1818, which determines the list of sectors considered to significantly contribute to climate change[1].
About agriculture sector
(i) Key position
We believe it is essential to include the agriculture sector and recommend adding the following NACE code to improve detail and transparency regarding deforestation-related risks:
- A.01.11: Growing of cereals, other than rice, leguminous crops and oil seeds (for soya beans)
- A.01.26: Growing of oleaginous fruits (for palm oil)
- A. 01.27: Growing of beverage crops (for cocoa and coffee)
- A.01.29: Growing of other perennial crops (for rubber trees)
- A.01.41: Raising of dairy cattle (for meat and milk)
- A.01.42: Raising of other cattle and buffaloes (for meat and milk)
ii. Supporting evidence et rational
This recommendation is based on recent regulatory developments and the need for enhanced transparency:
- On May 22 2025, the European Commission published the implementing regulation on the classification of countries by deforestation risk[2]. The regulation targets specific products for assessing country-level risks: cattle, cocoa, coffee, oil palm, natural rubber, soya, and wood.
- The proposed NACE codes align with these product categories and allow for better identification of activities linked to deforestation.
About the fossil fuel sector:
(i). Key position
We emphasise the importance of carefully revisiting the fossil fuel sector classification in the Pillar 3 disclosure framework. In particular, we recommend:
- Adding NACE code B08.92 – Extraction of peat, which is clearly linked to fossil fuel activities;
- Encouraging banks to provide their own breakdown between fossil and non-fossil fuels within D35.11 – Production of electricity from non-renewable sources, due to insufficient granularity in current classifications, consistently with the CPRS classification;
- Maintaining the use of NACE codes for fossil fuel exposure disclosure (preference for Option 1a, p. 46 of the consultation), as this promotes standardised and comparable data.
(ii). Supporting Evidence and Rationale
These recommendations are based on several considerations:
- The NACE classification system has inherent limitations and lacks the sectoral granularity required for Template 1 of the Pillar 3 framework, which itself has notable methodological shortcomings.
- In our analysis report, we used the CPRS framework from Battiston and al.(2017)[3] as a complementary reference, offering a more detailed mapping of climate-relevant economic activities and a more accurate view of fossil fuel exposure.
- For instance, the CPRS includes B08.92 – Extraction of peat in its definition of fossil fuel activities, but this code is not currently included in the proposed additions. The current inclusion of only B.08 is too broad and covers activities not directly related to fossil fuels.
- We welcome the inclusion of D35.11 – Production of electricity from non-renewable sources, but note that NACE Rev. 2.1 fails to distinguish between fossil and nuclear, limiting a reliable assessment of fossil fuel exposure.
- Despite its limitations, using NACE codes (rather than discretionary aggregates) still enables more standardised and comparable disclosures.
[1] COMMISSION DELEGATED REGULATION (EU) 2020/1818 of 17 July 2020 - (6) The sectors listed in Sections A to H and Section L of Annex I to Regulation (EC) No 1893/2006 of the European Parliament and of the Council ( 5 ), including the oil, gas, mining and transportation sectors, are sectors that highly contribute to climate change.
[2] https://ec.europa.eu/transparency/documents-register/detail?ref=C(2025)3279&lang=en
[3] Climate Policy Relevant Sectors
9. Do you have any views with regards to the update of the templates to NACE 2.1?
Relevant
10. Do you have any views with regards to NACE code K – Telecommunication, computer programming, consulting, computing infrastructure and other information service activities, and in particular K 63 - Computing infrastructure, data processing, hosting and other information service activities, whether these sectors should be rather allocated in the template under section Exposures towards sectors that highly contribute to climate change?
We agree with the addition of NACE code ‘K 63 – Computing infrastructure, data processing, hosting, and other information service activities’ as it may be associated with significant emissions due to the nature of the activities (e.g data center).
11. Do you have any comments on the inclusion of row “Coverage of portfolio with use of proxies (according to PCAF)”?
Relevant
12. Do you have any further comments on Template 1?
Consideration should be given to introducing the same template for flows, which would allow for more accurate monitoring of trends in exposures over time, for example with regard to new financing for fossil fuels.
13. Do you have any comments or alternative suggestions for SNCIs and other institutions that are not listed, regarding the sector breakdown?
No comment
14. Do you have any additional suggestions how to adjust Template 1A for SNCIs and other institutions that are not listed?
No comment
15. Do you have any further comments on Template 1A?
No comment
16. Should Template 2 in addition include separate information on EPC labels estimated and about the share of EPC labels that can be estimated?
(i) Key Position
We do not agree with the inclusion of separate information on EPC labels estimated and about the share of EPC labels that can be estimated
(ii) Supporting evidence and Rationale
Not relevant. Documenting the methodology for estimating EPCs would require significant resources, with limited regulatory value, as only official EPCs are recognised under frameworks like the EU Taxonomy. This would conflict with the EBA’s principle of proportionality. Moreover, in the absence of a standardised EU-wide methodology, banks would rely on varying approaches or data providers, undermining harmonisation and comparability.
17. Should rows 2, 3 and 4 and 7, 8 and 9 for the EP score continue to include estimates or should it only include actual information on energy consumption, akin to the same rows for EPC labels?
Not necessary, since row 5 and 10 provide information on the share of estimation.
18. Do you have any comments on the inclusion of information on covered bonds?
Yes, relevant
19. Do you have any comments on the breakdown included in columns b to g on the levels of energy performance?
Yes, relevant
20. Do you have any further comments on Template 2?
(i) Key Position
We agree with the EBA’s proposal to move column p next to column g, and to add a new column titled “Without EP score in kWh/m² of the collateral (neither measured nor estimated)”. In addition, we recommend a clear guidance on how to treat collateral which do not have an associated energy performance such as garages or land. We therefore recommend adding a column “not applicable” or “irrelevant energy performance”, to prevent from artificially increasing the amount of best performance collaterals.
(ii) Supporting evidence and Rationale
As highlighted in the consultation, there appears to be confusion between the EP score and the presence of an EPC label of the collateral. Reorganising the columns and explicitly identifying collateral which cannot have an energy performance assessment will improve clarity and consistency in reporting. For example, this year, Deutsche Bank classified collaterals such as garages or land under column b as '0 kWh/m²'.
21. Do you have any comments on Template 3?
(i) Key Position
We agree with the proposal to require a baseline year and to replace the [baseline year + 3 years] target with a 2030 target – and, where available, an additional target.
- We recommend including the sector breakdown recommended by the NZBA[1], which does not currently match Pillar 3 framework: agriculture, iron and steel, aluminum (separated from iron and steel), oil and gas, coal (separated from fossil fuel combustion), commercial and residential real estate.
- We recommend broadening the set of alignment metrics beyond GHG physical intensity, to include metrics more suited to certain sectors, such as technology/fuel mix and volume trajectory mix.
(ii) Supporting Evidence and Rationale
Requiring a 2030 target is appropriate given that most large banks have set their interim targets for 2030, as the majority are members of the NZBA, which defines interim targets at that horizon.
However, the removal of the sector list from column (a) raises concerns. If left to banks’ discretion, it would reduce the comparability and reliability of the data. The NZBA uses a more detailed sectoral breakdown than the one currently included in Pillar 3. Key NZBA sectors should be explicitly reintroduced into the template, as it appeared in the first 2022 template. This would ensure an appropriate level of granularity and, most importantly, alignment with current banking practices — thereby enhancing the consistency and comparability of banks’ reporting. Without such comparability, the usefulness of these reports for third parties, such as the Sustainable Finance Observatory, is significantly reduced.
Moreover, it is detrimental that metrics are restricted to GHG physical intensy. For some sectors, other alignment metrics are more relevant and allow for a more asset-based transition monitoring. For instance, the technology / fuel mix and volume trajectory mix for power, fossil fuels and automotive sectors[2].
Finally, template 3 is crucial in the sense that it is the only forward-looking data source from Pillar 3 ESG framework.
[1] Guidance for Climate Target Setting for Banks – Version 3
[2] See PACTA methodology : https://pacta.rmi.org/pacta-for-investors/metrics/
22. Do you have any comments with the proposals on Template 4 and the instructions?
(i) Key Position
We recommend that the EBA mandate a single, official reference list. In our view, the "Carbon Majors" list published by the Climate Accountability Institute represents the most reliable option, as it is updated annually and includes part of Scope 3 emissions .
(ii) Supporting Evidence and Rationale
The lists currently used are not harmonized across institutions. Each data provider applies its own methodology, particularly in terms of the inclusion of Scope 1, 2, and 3 emissions, and the reference years covered often differ. This lack of consistency creates a risk of data arbitrage, whereby a bank could intentionally select a source that omits certain major carbon-intensive counterparties from its portfolio.
Extract from our analysis report:
The table below displays most used top 20 emitting firms lists by European banks for the Template 4 and shows the disparities between them. Firms in red are present in only one of the three lists, firms in yellow in two and firms and firms in green in the three.
Only 5 firms are present in all the lists used and 23 firms are present in only one list.
[See PDF file of our response to access the table on https://sustainablefinanceobservatory.org/]
23. Do you have any views on whether this template could be improved with some more granular information in the rows, by requesting e.g. split by sector of counterparty or other?
We strongly agree with this suggestion for more granularity in Template 4 by introducing a sectoral breakdown. However, we question its feasibility from the perspective of banking confidentiality requirements. In our view, the most important aspect remains the establishment of a common, mandatory list.
24. Do you have any further comments on Template 4?
We suggest that this template also be reported by the other listed institutions and large subsidiaries, at least on an annual basis as it is not complex to report.
25. Do you have any comments on the proposal using NUTS level 3 breakdown for Large institutions and NUTS level 2 for Other listed institutions and Large subsidiaries? Would NUTS level 2 breakdown be sufficient for Large institutions as well?
(i) Key Positions
We warmly welcome changes made in the template 5, making it much clearer and usable for third party observer. Replacement of acute and chronic events breakdown by thematic hazards is a valuable improvement
However, we recommend replacing the proposed NUTS 3 geographical breakdown with a more proportionate approach. Specifically, we suggest:
- Requiring a version of Template 5 on total assets without geographical specification;
- Introducing only three geographical categories: country of residency of the institution, Europe, and rest of the world.
(ii) Supporting Evidence and Rationale
The change in geographical breakdown is likely to bring complexity and a significant reporting burden for banks. Given our experience of analysing template 5 reporting, appropriating these data takes time, and the current maturity in reporting and in using such reports for transition steering and physical risk management appears insufficient, at this stage, to justify requiring such detailed geographical breakdown. The issue with focusing solely on a sample of sensitive geographical areas is that it prevents a comprehensive view of the physical risks borne by the institution. Potentially, a combination of a broad and complete breakdown along axis Z, together with a targeted breakdown for sensitive NUTS regions, could address this limitation.
26. Do you have any comments on the instructions for the accompanying narrative and on whether they are comprehensive and clear?
No comment
27. Do you have any further comments on Template 5 and on its simplified version Template 5A?
Same comments as for template 5.
28. Do you have any comments on the proposal to fully align templates on the GAR, that is, templates 7 and 8, with those under the Taxonomy delegated act by replacing the templates with a direct cross reference to the delegated act?
(i) Key Position
We recommend to require banks to report GAR (flow) KPI in gross carrying amounts rather than in percentage - this does not appear to be provided for in the taxonomy according to Commission delegated regulation (EU) 2021/2178.
We have also a general concern regarding the exclusion of non-CSRD companies from the GAR.
(ii) Supporting Evidence and Rationale
As the Omnibus proposal significantly reduces the scope of CSRD application, the taxonomy/GAR ratios are now likely to reflect only a small proportion of banks' portfolios, thereby preventing a broad interpretation of these ratios at the EU economy level.
Extract for our analysis report
Regarding asymmetry between numerator and denominator in the GAR calculation
Our analysis on 15 banks showed that 34% of total assets are included in the denominator but excluded from the numerator. This asymmetry may be perceived as penalizing for banks, particularly those whose activities are diversified beyond the scope of European regulations. We showed also that only 30% of the total assets of the banks in the sample are included in both the numerator and the denominator. In other words, only this portion is subject to an analysis of eligibility or alignment with the taxonomy.
The Green Asset Ratio tends to be lower when the share of assets included in the denominator but excluded from the numerator (blue) is higher than assets included in both numerator and denominator (green).
While the exclusion of non-CSRD companies from the denominator — as proposed in this consultation — may address the numerical asymmetry, it also significantly reduces the overall scope of the GAR.
[See PDF file of our response to access the graphs on https://sustainablefinanceobservatory.org/]
29. Do you have any comments on the proposal related the BTAR and to keep it voluntary?
No comment
30. Do you have any comments regarding the adjustments to template 10?
No comment
31. Do you have any further comments on the Consultation Paper Pillar 3 disclosures requirements on ESG risk?
No comment
32. Are the new template EU SB 1 and the related instructions clear to the respondents? If no, please motivate your response.
No comment
33. Do the respondents agree that the new template EU SB 1 and the related instructions fit the purpose and meet the requirements set out in the underlying regulation?
No comment
34. Are the amended template EU CR 10.5 and the related instructions clear to the respondents? If no, please motivate your response.
No comment
35. Do the respondents agree that the amended template EU CR 10.5 and the related instructions fit the purpose and meet the requirements set out in the underlying regulation?
No comment
36. Do the respondents consider that the “mapping tool” appropriately reflects the mapping of the quantitative disclosure templates with supervisory reporting templates?
NA