EU: EBA publishes long-awaited final draft ITS amending the Pillar 3 disclosure framework on ESG risks

On 22 June 2026, the European Banking Authority published its long-awaited final draft ITS amending the Pillar 3 disclosure framework on ESG risks, and introducing disclosure requirements on equity and shadow banking exposures. 

With regard to ESG-related risks disclosures, and in line with the CRR3 mandate, the amending ITS extends the scope of institutions required to disclose ESG information, covering not only large, listed institutions but also large non-listed and other institutions, SNCIs, and large subsidiaries. At the same time, and consistent with the EBA’s objective of simplifying and enhancing proportionality in the supervisory framework, as well as the broader EU agenda on regulatory simplification, the EBA says that it is taking a proportionate and streamlined approach to ESG disclosures. 

Key aspects of the Final Draft amending ITS presented in this Final report include, regarding ESG
related disclosures: 

• A simplified and proportionate approach based on the size and complexity of institutions: the EBA proposes a tailored framework with different sets of templates depending on the type of institution. SNCIs are required to disclose only essential information on ESG risks, including physical and transition risks and exposures to fossil fuel sectors. A proportionate approach is also applied to other institutions and large subsidiaries.
• No new requirements but enhanced clarity on the disclosures of large institutions: the proposal improves and clarifies the existing disclosure requirements for large listed institutions, based on the Questions and Answers (Q&As) received by the EBA regarding Pillar 3 ESG framework currently in place. While the core information remains broadly  unchanged, the revisions enhance clarity and usability.
• Consideration of JBRC recommendations to enhance consistency across reporting 
  frameworks: the EBA has assessed the JBRC recommendations on ESG semantic integration and has incorporated, where appropriate, those improving consistency in terminology, and clarifications in instructions, while others have been only partially considered or deemed out of scope. 

The Final ITS are aligned with the European Sustainability Reporting Standards (ESRS) and with the EBA draft ITS on ESG supervisory reporting requirements, which are currently under consultation (see our blog post here). They should, therefore, be read in conjunction with the EBA's earlier consultation paper to ensure a comprehensive understanding of the overall ESG framework and to support informed feedback.

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.
• 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.

The EBA press release with links to the templates is available here.