EBF PROPOSAL

EBF Proposal for a Phased-in Implementation of the EBA ESG Risk Management Guidelines

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Brussels, 11 June 2025 – The European Banking Federation has submitted a proposal to EU policymakers calling for a phased-in implementation of the EBA Guidelines on ESG Risk Management.

European banks remain firmly committed to strengthening ESG risk management. However, while welcoming the EBA’s objective of strengthening ESG risk management practices, the EBF highlights that the current implementation timeline is not realistic due to significant data, methodological, and operational challenges—many of which are being exacerbated by the ongoing Omnibus review and changes to the CSRD scope.

Key concerns include:

• Data limitations, especially for nature-related and S&G risks, worsened by the exclusion of many firms from CSRD reporting obligations;
• Immature methodologies and evolving standards, particularly around ESG risk quantification and portfolio alignment;
• The need for substantial internal adjustments, such as IT system overhauls and governance reforms;
• Misalignment with pending supervisory guidance, notably the forthcoming EBA Guidelines on ESG Scenario Analysis.

On this backdrop, the EBF proposes the postponement of the ESG Risk management Guidelines’ application deadline – along with that of the upcoming guidelines on ESG Scenario Analysis – until the Omnibus amendments are finalized, and a revision of the EBA Guidelines in the spirit of the Omnibus simplification and for consistency with the final versions of the CSRD/ESRS1 and CSDDD.

Should it be impossible to defer the implementation date of the EBA ESG Risk Management (and ESG Scenario Analysis Guidelines), we would urge supervisory authorities to issue a public statement supporting phased implementation, and to consider a no-action letter during this transition period.

To support this proposal, the EBF has shared with key policy makers a three-phase approach to implementation, aligned with the maturity of the requirements and institutions’ readiness.

EBF stresses that this is not a step back from ESG integration, but a pragmatic proposal to ensure high-quality, consistent, and effective adoption across the sector.

You can access the full EBF proposal here.

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About the EBF:

The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.