EBA publishes no-action letter on ESG disclosure enforcement and updates ESG risk dashboard
The European Banking Authority (EBA) has published a no-action letter concerning the application of environmental, social and governance (ESG) Pillar 3 disclosure requirements under its Implementing Technical Standards (ITS). The letter, formalised through an accompanying Opinion (EBA/Op/2025/11), aims to address legal and operational uncertainties linked to the evolving ESG disclosure framework, in light of proposed amendments under the European Commission’s Omnibus legislative package on sustainability reporting. These proposed amendments affect several legislative instruments, including Directive 2014/95/EU (Non-Financial Reporting Directive), Directive (EU) 2022/2464 (Corporate Sustainability Reporting Directive), Directive (EU) 2024/1760 (Corporate Sustainability Due Diligence Directive), and Regulation (EU) 2020/852 (Taxonomy Regulation). The EBA also published an updated ESG risk dashboard based on December 2024 data, which indicates that the ESG risk landscape across EU/EEA banks remains stable, reflecting the long-term horizon of climate-related risks and the gradual pace of change in banking portfolios.