The EACB welcomes the opportunity to comment on the EBA draft ITS amending the EBA Pillar 3 disclosures framework by incorporating the Regulation (EU) 2024/1623 (CRR 3) requirements on ESG related risks, equity exposures and the aggregate exposure to shadow banking entities and finalising the implementation of the prudential disclosure requirements. We commend the emphasis placed on materiality, proportionality and risk-based reporting in line with the diversity of institutions and business models across the EU.
Ensuring that SNCIs are not overburdened by disclosure requirements will help preserve the competitiveness of locally active banks while still upholding transparency and achieving market discipline. We would also suggest clarifying in the draft text that the ESG disclosure requirements for SNCIs have to be met only once the reporting system has been implemented, in accordance with Article 433(b) of the CRR 3. In practice, this means that initial disclosure in 2026 will be unfeasible for these institutions. Moreover, we would like to point out that Article 449a (3) sentence 2 of the CRR 3 specifies that for all institutions the disclosure requirements must not exceed the reporting requirements.
In this vein, we appreciate the EBA’s design of transitional provision to allow a phased implementation of the new requirements that sets out a clear approach also for institutions that are already producing ESG risks disclosures.
We also emphasise the importance of ensuring coherence between key frameworks such as Pillar 3 and ESG risk management guidelines, as well as the Green Asset Ratio (GAR), the ESRS and the EU Taxonomy. In this regard, the EACB welcomes the EBA’s proposal to integrate, in terms of necessary information, the so-called value chain cap that makes the VSME standard the reference point for sustainability information in the context of CSRD – for small and medium-sized enterprises. This is in line with an efficient and streamlined approach, and the cross-reference across pre-existing standards.
Looking forward, the EACB encourages the EBA to continue applying the same approach as it further develops the reporting and disclosure frameworks. Aligning future obligations with ongoing EU legislative initiatives and supervisory reporting requirements will be crucial in minimising overlaps and administrative burdens, thereby facilitating coherent implementation across the financial sector.