EBA consultation on draft technical standards on Pillar 3 disclosures of ESG risks: EBF response
Publication date: 2 June 2021
Key messages
Please find below a few key points of the EBF response on the EBA consultation on draft technical standards on Pillar 3 disclosures of ESG risks:
- Article 8 reporting requirements should not be included in the Pillar 3 scope and only disclosed under the Taxonomy Regulation Delegated Act.
- ESG Pillar 3 content, scope, and frequency should be aligned with NFRD/ CSRD content, scope, and frequency.
- The ITS requirements should be simplified, aligned with the objective of public risk disclosures, and reflect the maturity of methodological developments as well as the availability of relevant and reliable data. A meaningful reporting to supervisors/survey should be explored until robust methodologies for banks are developed at the EU level.
- The disclosures should focus on the exposures of the banking book which represent the vast majority of banks’ risks.
- We recommend that EBA develops a Pillar 3 approach by building blocks. It should commence with a limited number of ‘core’ templates based on available and high-quality data and methodologies and gradually, the level of granularity should be adapted.
For more information:
Denisa Avermaete, Senior Policy Adviser, Sustainable Finance, d.avermaete@ebf.eu
Eleni Choidas, Policy Adviser, Sustainable Finance, e.choidas@ebf.eu
About the EBF:
The European Banking Federation 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. The EBF serves as the voice of the European banking sector, bringing together national banking associations from across Europe. Website: www.ebf.eu Twitter: @EBFeu.
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]]>EBF advisor: Gonzalo Gasos
Publication date: 14 March 2019
Executive summary
In recent months, supervisors and regulators have become increasingly concerned about potential window-dressing practices. The concern of supervisors is that some banks do not live up to their responsibility to maintain a sufficiently high leverage ratio and only meet the leverage ratio requirement when they have to report to supervisors. Several comments have sparked a debate on the global and European level that prompted the BCBS to launch a consultation with the aim to prevent those practices.
The EBF encourages supervisors to use their powers to enforce this requirement on an entity-specific basis. Furthermore, the EBF deems it important to further analyse and gain a better understanding of the market dynamics that could potentially indicate window-dressing. Those measures are necessary to limit the regulatory impact of those measures on banks that are compliant with the leverage ratio requirements. Moreover, the EBF believes that the final standards of the BCBS should be applied according to the local proportionality rules.
EBF contact:
Gonzalo Gasos, Head of Banking Supervsion, g.gasos@ebf.eu
Lukas Bornemann, Prudential Policy and Supervision, l.bornemann@ebf.eu
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]]>Advocating for a global level playing field for banks, the European Banking Federation’s Pillar III Working Group meets on a regular basis to discuss disclosure requirements of banks at global and European level. It delivers well-informed advice to strike the right balance between transparency, simplicity and understandability of public disclosure efforts by banks.
This spring, the EBF Pillar III working group gathered for the seventh time, after four years, at the EBF Brussels offices. The group discussed the European Commission’s recent consultation on Pillar 3 disclosure requirements. Members elaborated their current concerns on introducing the so called standardised approach as a benchmark to calculate risk-weighted assets. Other matters of interest were the implementation of new templates, issued by the Basel Committee, for asset encumbrance as well as credit distribution constraints. While the group agrees with several proposed amendments made to the templates. However, the group expressed recurring doubts about some specific requirements that could impact the level playing field for banks and affecting the comparability of their public information. With the deadline of 26 May, the EBF will finalise together with its members the response to the consultation in the following weeks.
Banks and banking associations represented in the Working Group include the Finnish, French and German banking associations, and HSBC, Deutsche Bank, BBVA, Intesa Sanpaolo.
EBF positions and communucations coming out of this working group will be published on this page.
Subscribe to the EBF Weekly + FinReg Agenda
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
Subscribe to the EBF Morning Brief
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
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