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EBF response to European Commission consultation on Taxonomy Disclosures Delegated Act

Brussels, 28 March 2025 – The European Banking Federation (EBF) has submitted its response to the European Commission’s consultation on the Taxonomy Disclosures Delegated Act. While welcoming the initial steps toward simplification, EBF highlights that substantial challenges for banks remain.

The EBF acknowledges that the proposed changes under the Disclosures Delegated Act (DDA) bring some simplification for banks. However, key complexities persist, par

The European Banking Federation (EBF) has submitted its response to the European Commission’s consultation on the Taxonomy Disclosures Delegated Act.

ticularly in the following areas:

• Technical screening criteria and related assessments under the EU Taxonomy: The “Do No Significant Harm” (DNSH) criteria and the “Minimum Safeguards” (MS) provisions have not been simplified and remain highly complex to evaluate.
• Data collection from retail clients: Although mid-cap companies are exempt from reporting obligations, banks are still expected to gather EU Taxonomy data from retail customers (for example, on mortgages or car loans), including information related to DNSH and MS. In most cases, this data is unavailable or cannot be reliably documented by retail clients.

EBF further notes that the temporary nature of the proposal, introduced under the Omnibus initiative, entails significant operational implications. Banks would be required to invest in data infrastructure and processes that may soon become obsolete with the final revision of the Green Asset Ratio (GAR). As such, the temporary solution, while well-intentioned, imposes additional burdens and costs.

Given that the proposed simplification does not fully address the challenges of GAR reporting, that it will soon be replaced by a more comprehensive review, and that it imposes significant costs and creates confusion due to multiple reporting frameworks (including duplicate GAR disclosures under both the Disclosures Delegated Act and Pillar 3), EBF recommends the suspension of GAR reporting obligations under Article 8 of the Taxonomy Regulation for the Corporate Sustainability Reporting Directive (CSRD), until the full review is completed. Additionally, GAR reporting should be removed from the Implementing Technical Standards (ITS) on Pillar 3 disclosures on ESG risks.

When it comes to its final design, the Green Asset Ratio needs to be further simplified to increase usability and comparability and decrease reporting burden. In terms of companies, GAR should only cover companies that fall under the CSRD. Other assets, except retail exposures, special purpose vehicle (SPV) and special purpose entity (SPE) for which an EU Taxonomy alignment ratio has been identified, should be removed from the Green Asset Ratio – both the numerator and the denominator. Retail exposures should only be assessed for Substantial Contribution under a simplified assessment procedure. The “Do no Significant harm” (DNSH) criteria and The Minimum Safeguards (MS) provision for retail exposure should not be required. All templates, except of 0 and 1 should be removed.

These recommendations aim to reduce the compliance burden and ensure that GAR reporting becomes a more effective, proportionate, and comparable tool across the banking sector.

For more information and media inquiries:

Denisa Avermaete, Head of Sustainable Finance, d.avermaete@ebf.eu

Janis Priekulis, Policy Adviser – Financing Sustainable Growth, j.priekulis@ebf.eu

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.