Publications • July 24, 2025
Response to EBA Consultation on Pillar 3 ESG Reporting Framework
This note presents our key positions and recommendations on the following aspects of the Pillar 3 disclosure framework:
Contributors
Edouard Vilpoux
Lead Sustainable Finance Economist - The Sustainable Finance Observatory
This publication is part of the following programs: ADEME SFO Partnership
On the scope of institutions, proportionality and simplification measures
The overall simplification is welcome, particularly the reduced reporting frequency and a proportionate, gradual approach for listed subsidiaries, SNCI and non-listed institutions.
On transitional provisions introduced in the ITS and interim guidance until the finalisation of the ITS
We strongly disagree with the suspension of GAR reporting for 2025 and 2026. While we acknowledge the significant methodological challenges in calculating the GAR, suspending reporting would create a gap in transparency and accountability regarding European banks’ contribution to financing green activities.
Suspending it would set a precedent that risks undermining the future of taxonomy-based ratios at the banking level—similar to recent delays in CSRD and CSDDD, which raise concerns about potential rollbacks.
On review of the quantitative information on ESG
Enhance fossil exposure reporting by aligning with the CPRS classification, introduce more granularity for agriculture, and include including both stock and flow data.
Ensure greater ambition in Template 3 regarding the list of covered sectors, the NACE codes involved and interoperability with the NZBA framework
Include additional forward-looking indicators (e.g. technology mix, volume trajectory) beyond financed emissions, which are currently insufficient on their own.
Establish a single reference list for identifying exposures to top emitting firms to ensure consistency across institutions.
Avoid over-complexity in Template 5: replace NUTS 3 regional granularity with a more feasible breakdown by country, Europe, and Rest of World.