Main point:
EBA (European Banking Authority) just released a no action letter, recommend to the management agencies not prioritizing the implementation of ESG Pillar 3 disclosure requirements for banks, pending results from the initiative Bus I of the European Commission.
According to the Banking Package (CRR3) Issued in 2024, from 2025 banks must publish:
Environmental risks (physical and transformation), social and governance risks.
Exposure to fossil fuel sector.
How to integrate ESG into strategy, business processes, governance and risk management.
The scope of disclosure is expanded from large banks to all credit institutions, even small.
Reason for delay:
February 2, EC announced Bus I, propose reduce the burden of sustainability reporting with major changes to CSRD, CSDDD, Taxonomy and CBAM.
The EBA is also adjusting its banking reporting rules to bring them into line with Bus I.
If implemented immediately, the bank may encounter:
Conflicting reports (eg Green Asset Ratio by Taxonomy).
The compliance burden is too great, especially for small banks that have to disclose for the first time.
EBA key messages:
“The EBA is committed to developing a consistent and coherent ESG disclosure framework, and will work closely with EU agencies and stakeholders to ensure its smooth implementation.”
📌 Implications for business & banking:
Temporary reduce short-term compliance pressure, but that doesn't mean ESG reporting is dead — it's just waiting for "streamlining" and synchronization.
Banks (especially in the EU) should still Preparing ESG data management capabilities, because in the long run reporting will become mandatory.
Businesses that borrow from or partner with European banks will also be affected, as banks need ESG data from clients to complete their own reports.