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EU Green Bond Regulation: ESMA consults on rules for External Reviewers of European Green Bonds

On 26 March 2024, the European Securities and Markets Authority (ESMA) launched a consultation on technical standards relating to the registration and supervision of external reviewers interested in becoming external reviewers of European Green Bonds, aiming to clarify the criteria used for assessing an application for registration by an external reviewer and standardise these registration requirements. 

The draft technical standards relate to: 

  • criteria to be assessed at the time of registration relating to senior management, board members and analytical resources;
  • criteria to assess sound and prudent management and management of conflicts of interest; 
  • criteria for assessing knowledge and experience of analysts;
  • criteria applicable to outsourcing of assessment activities; and 
  • the standard forms, templates and procedures for the provision of registration information under the EU Green Bond Regulation.  


The Regulation on European Green Bonds and optional disclosures for bonds marketed as environmentally sustainable and for sustainability-linked bonds (the EU Green Bond Regulation) was published in the Official Journal of the European Union on 30 November 2023, entered into force on 20 December 2023 and will apply from 21 December 2024. 

The EU Green Bond Regulation introduces: (i) a voluntary label for issuers of green use of proceeds bonds where proceeds are fully allocated to economic activities aligned with the EU Taxonomy Regulation (subject to some limited flexibility); and (ii) creates an optional disclosure regime for bonds marketed as environmentally sustainable and sustainability-linked bonds. 

For issuers wishing to use the voluntary label (i.e. issuers of European Green Bonds), there are prescribed pre- and post-issuance transparency requirements, including the completion of a pre-issuance European Green Bond factsheet, post-issuance European Green Bond allocation report(s) and post-allocation European Green Bond impact report, each following templates set out in the Regulation. 

Issuers of European Green Bonds will also be required to contract an independent external reviewer to provide a pre-issuance review of the European Green Bond factsheet and a post-issuance review of the European Green Bond annual allocation reports. 

These external reviewers must be registered with and supervised by ESMA. Pursuant to the EU Green Bond Regulation, ESMA has been tasked with developing draft regulatory technical standards (RTS) and implementing technical standards (ITS)relating to the registration and supervision of external reviewers of European Green Bonds on which it is now consulting.

Next steps

The consultation is open until 14 June 2024. ESMA will then consider the feedback received and submit the draft RTS and ITSs to the European Commission by 21 December 2024.

For more detail on the European Green Bond Regulation, see our earlier blog post and our podcast series, including episode six, which explains the regime for external reviewers of European Green Bonds in a nutshell. 


asset managers & funds, banks & insurers, bonds, sustainable finance, eu-wide, blog posts