EBA Updates Pillar 3 Disclosure Requirements On ESG Risks, Equity And Shadow Banking Exposures, As Part Of Simplification Effort

The European Banking Authority (EBA) has published today its final draft Implementing Technical Standards (ITS) amending the Pillar 3 disclosure framework on environmental, social and governance (ESG) risks, and introducing disclosure requirements on equity and shadow banking exposures. The package finalises the implementation of the disclosure requirements introduced by the Capital Requirements Regulation (CRR 3). Developed in line with the EU’s simplification agenda and the Omnibus package, the ITS streamline existing requirements, and enhance usability and consistency. The ITS are aligned with the European Sustainability Reporting Standards (ESRS) and with the EBA draft ITS on ESG reporting requirements, which are currently under consultation. They should, therefore, be read in conjunction with this Consultation paper to ensure a comprehensive understanding of the overall ESG framework and to support informed feedback.

Link between ESG supervisory reporting and Pillar 3 disclosure framework

The final draft ITS on Pillar 3 disclosures on ESG risks are closely linked to the ESG supervisory reporting framework set out in the related consultation paper.

To fully understand the proposed scope and requirements, stakeholders are encouraged to consider both documents together.

Interoperability with other sustainability reporting frameworks

The EBA has closely followed the simplification of the European Sustainability Reporting Standards (ESRS) under the Corporate Sustainability Reporting Directive (CSRD), and these ITS are aligned accordingly. Interoperability between the two frameworks enables institutions to use—and where appropriate cross-refer to—information disclosed under Pillar 3 in their ESRS public reporting, thereby reducing duplication.

The EBA stands ready to cooperate closely with the European Commission to further strengthen alignment with ESRS, as needed, while ensuring a smooth adoption process.

Proportionality and simplification of ESG disclosure requirements

The amending ITS enhance the existing disclosure requirements on ESG-related risks applicable to large institutions and, for the first time, extend ESG disclosure requirements to all institutions in a proportionate manner, as required by CRR 3.

For large institutions, the ITS build on and simplifies the requirements already in place. The ITS introduce a “core plus supplement” approach, calibrated to institutions’ size and complexity. As a result, large institutions will disclose 37% less datapoints than now and the taxonomy related disclosures are stopped. Other (medium) institutions will disclose 17% less, and Small and Non-Complex Institutions (SNCI) 84% less datapoints than large institutions, respectively. Furthermore, the EBA will centrally pre-fill and disclose ESG information in the Pillar 3 Data Hub on behalf of SNCIs based on supervisory reporting.

The ITS also incorporate the recommendations of the Joint Bank Reporting Committee (JBRC) on semantic integration, ensuring integrated reporting.

Next steps

The EBA will submit the final draft ITS to the European Commission for adoption. It will also develop a Data Point Model (DPM) and XBRL taxonomy required for the submission of the information to the Pillar 3 Data Hub. In addition, the EBA will publish an updated mapping tool in 2026, linking Pillar 3 disclosures with supervisory reporting.

The ITS are expected to apply with a reference date of 31 December 2026, and 31 December 2027 for SNCIs – this notwithstanding any further adjustment needed as a result of the finalisation of Commission’s work.

Legal basis and background

Today’s publication contributes to the EBA’s communication campaign “Simplifying to strengthen: building a more efficient EU prudential and supervisory framework”. This initiative is part of the EBA’s broader priority to simplify and enhance the efficiency of the regulatory and supervisory framework, in line with the work of its Task Force on Efficiency (TFE) and the EBA’s Report on the efficiency of the regulatory and supervisory framework, published on 1 October 2025. It delivers, in particular, on Recommendations 4 (Integrated reporting), and 5 (Review and reduce existing reporting requirements) aimed at reducing costs and improving proportionality.

Regulation (EU) 2024/1623 (CRR3) amending Regulation (EU) No 575/2013 implements the Basel III post-crisis reforms in the EU, taking into account the specific features of the EU banking sector. The deliverable forms part of the 'EBA Roadmap on strengthening the prudential framework', published in December 2023. Following the adoption of Commission Implementing Regulation (EU) 2024/3172 as step 1 of the roadmap, these ITS represent step 2, amending the Pillar 3 disclosure framework to reflect additional CRR3 changes, including:

• disclosures on equity exposures (Article 438(e) CRR3);
• disclosures on aggregate exposures to shadow banking entities (Article 449b CRR3); and
• the extension of ESG risk disclosure requirements to all institutions (Article 449a CRR3).

The final report repeals the Guidelines on non-performing and forborne exposures, reflecting the incorporation of these disclosures into the CRR framework, notably through Articles 433b and 433c of CRR3.