The EACB welcomes the opportunity to comment on the EBA Draft Guidelines on the management of ESG risks. We appreciate the effort to give institutions clarity on the expectations substantiating the CRD requirements before setting out the implications in terms of SREP process and supervisory actions, however we urge the EBA to avoid an overly prescriptive approach that would essentially constrain the institutions’ learning curve in the management of ESG risks.
We also appreciate that the choice to keep the focus of the draft GLs especially on environmental aspects, given the early stages of development of approaches for the “S” and “G” dimensions.
We have several suggestions with regard to proportionality aspects (particularly touching upon the frequency of the materiality assessment), and the need for some additional clarifications in terms of expected outcomes/approaches.