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]]>EBF ESG Risk management documents
- EBF Proposal for a Phased-in Implementation of the EBA ESG Risk Management Guidelines
- EBF Response to the EBA consultation paper on Climate Scenario Analysis
- EBF Response to the BIS discussion paper on the role of climate scenario analysis in strengthening the management and supervision of climate-related financial risks
- EBF Response to the EBA Consultative Document Guidelines on ESG risks management
- One-off Fit-for-55 climate risk scenario analysis EBF response to the EBA consultation
- EBF response to the EBA Discussion Paper on the role of environmental risks in the prudential framework
- Pillar 1 capital charge for climate risk: Wrong tool for the right purpose
- EBF response to BCBS Consultation ‘Principles for the effective management and supervision of climate-related financial risks’
- Management and supervision of ESG risks for credit institutions and investment firms: EBF response to EBA consultation
- EBF position on the ECB Guide on Climate Risk
- EBF response to the ECB consultation on the Guide on Climate related and Environmental Risks
- EBA consultation on draft guidelines on loan origination and monitoring: EBF response
- EBF Incentives Report
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]]>EBF CONSULTATION RESPONSE
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EBF Calls for Pragmatic Simplification of European Sustainability Reporting Standards
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BRUSSELS, 6 May 2025 – The European Banking Federation (EBF) has submitted its detailed response to EFRAG’s consultation on the simplification of Set 1 of the European Sustainability Reporting Standards (ESRS). In its response, the EBF emphasizes the need for a pragmatic, principles-based approach that ensures meaningful sustainability reporting without imposing disproportionate burdens on preparers, especially within the banking sector.
The EBF’s key recommendations include:
- Practical over aspirational: Focus on mature topics with established methodologies and decision-useful data points
- Cost and effort consideration: Incorporate the “undue cost or effort” principle applied by the ISSB
- Principles-based flexibility: Allow preparers to determine what information is disclosed and how it is structured, within a clear reporting framework
- Simplification of materiality:
– Streamline materiality assessments to focus only on topics relevant to company strategy, business models, and activities
– Prioritize information materiality to ensure only relevant data is disclosed
– Remove data points that no longer serve a clear materiality purpose - Clarity and comparability: Strike a balance between principles-based flexibility and the need for consistency across disclosures
- Structural simplification: Eliminate duplications within and across standards, and align with other regulations such as Pillar 3 and annual reporting requirements
- Aggregation and alignment:
– Allow disclosures at the key sustainability topic level (e.g. Climate, Environment)
– Align consolidation scope with financial reporting to avoid subsidiary stand-alone reporting obligations
– Specify that disclosures are not required if data is unreliable or no common methodologies exist
Sector-Specific Recommendations for Financial Institutions
The EBF also highlights banking-specific considerations:
- Cap the value chain for Double Materiality Assessment to tier one CSRD entities only
- Align methodologies, time frames, and definitions for materiality assessments with regulatory requirements and allow residual risk approaches
- Align time horizons and topic aggregation with standard banking practices
- Exempt banks from reporting data points irrelevant to the banking sector
- Foster close collaboration between EFRAG, EBA, the European Commission, and other stakeholders to ensure methodological alignment with related EU legislation, including SFDR and EBA supervisory requirements, avoiding duplicative reporting
The EBF stands ready to continue its active engagement with regulators and standard-setters to ensure the ESRS remains clear, relevant, and proportionate, ultimately supporting sustainable finance and transparency without compromising operational feasibility for banks.
For more information please contact:
Denisa Avermaete, Head of Sustainable Finance, D.Avermaete@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.
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]]>The omnibus simplification initiative of the European Commission is an opportunity to refocus on the core elements that are needed to achieve the EU environmental objectives. It is a logical step in the context of the European Commission’s policies and initiatives outlined in the recently published competitiveness compass. Europe’s global competitiveness and climate goals can and should go hand in hand.
The European Commission’s Omnibus Simplification Initiative is a significant step towards aligning Europe’s competitiveness with sustainability. The EBF has outlined key recommendations to ensure the Omnibus Simplification Initiative achieves its goals without compromising the EU’s sustainability and competitiveness objectives.
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 European Banking Federation (EBF) has submitted a letter to the European Commission, European Banking Authority (EBA), and the European Central Bank (ECB) regarding the ongoing ESG Omnibus initiative. In the letter, the EBF welcomes the simplification efforts but stresses the need for these changes to be fully reflected in financial sector regulation and supervision. The letter highlights the importance of clear communication, streamlined ESG risk management expectations, and better facilitation of ESG data access.
EBF proposal for changes to the Corporate Sustainability Reporting Directive 2013/34/EU (CSRD)
ESRS Set 1 revision: Questionnaire for public feedback – EBF RESPONSE
The European Banking Federation (EBF) urges EFRAG to simplify the European Sustainability Reporting Standards (ESRS) by adopting a more practical, principles-based approach that reduces complexity, aligns with existing financial reporting frameworks, and minimizes undue costs and efforts for preparers, particularly in the banking sector.
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]]>EBF POSITION
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Position of the European Banking Federation on the Omnibus Initiative
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Brussels, 28 March 2025 – The European Banking Federation (EBF) welcomes the European Commission’s efforts to simplify sustainability reporting through the Omnibus initiative. In its latest position, the EBF calls for the suspension of Green Asset Ratio (GAR) reporting obligations under the Corporate Sustainability Reporting Directive (CSRD) until the full review of the EU Taxonomy Delegated Acts is completed. The EBF also advocates limiting mandatory value chain reporting to companies within the CSRD scope, ensuring consistency across financial sector regulations, and applying ESG reporting requirements only at the group level. These changes are vital to reduce complexity, lower costs, and support a more effective and practical transition to sustainable finance.
You can read the full document here.
For more information:
Denisa Avermaete, Senior Policy Adviser – Sustainable Finance, D.Avermaete@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.
Stay in touch with the EBF
The EBF produces a daily and a weekly newsletter with European banking news and updates from national banking associations across Europe. CLICK HERE TO SUBSCRIBE
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]]>EBF POSITION PAPER
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Simplification of the EU Sustainable Finance Framework Omnibus Legislative Proposal Proposal
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Brussels, 4 February 2025 – The omnibus simplification initiative of the European Commission is an opportunity to refocus on the core elements that are needed to achieve the EU environmental objectives. It is a logical step in the context of the European Commission’s policies and initiatives outlined in the recently published competitiveness compass. Europe’s global competitiveness and climate goals can and should go hand in hand.
The omnibus simplification initiative of the European Commission is an opportunity to refocus on the core elements that are needed to achieve the EU environmental objectives.
Banks are both users and preparers of data; therefore, they will always need certain data for running sound business and risk management. Removing core data from the CSRD or removing companies from its scope altogether will not serve the simplification objective, as it will result in a need for bilateral engagement with clients. Nevertheless, there is room for substantial simplification, which must take the symmetry between corporate reporting and requirements for the financial sector into account. Financial institutions should not be required to report or collect data not reported or not considered material by their clients themselves, nor should they report on customers that are not subject to any reporting obligation. Neither should banks be expected to report data and ratios that are not decision-useful, comparable, or faithfully representative.
The views of the banking industry and proposals for simplification can be found here.
For more information:
Denisa Avermaete, Senior Policy Adviser – Sustainable Finance, D.Avermaete@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.
Stay in touch with the EBF
The EBF produces a daily and a weekly newsletter with European banking news and updates from national banking associations across Europe. CLICK HERE TO SUBSCRIBE
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]]>EBF LETTER
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EBF Submits Letter to EU Institutions on ESG Regulatory Simplification
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Brussels, 1 April 2025 – The European Banking Federation (EBF) has submitted a letter to the European Commission, European Banking Authority (EBA), and the European Central Bank (ECB) regarding the ongoing ESG Omnibus initiative. In the letter, the EBF welcomes the simplification efforts but stresses the need for these changes to be fully reflected in financial sector regulation and supervision. The EBF calls for a comprehensive review of ESG-related regulations to ensure consistency with the Corporate Sustainability Reporting Directive (CSRD) and urges suspension of certain reporting obligations to avoid unnecessary complexity and costs for banks. The letter highlights the importance of clear communication, streamlined ESG risk management expectations, and better facilitation of ESG data access.
You can read the full letter here.
For more information:
Denisa Avermaete, Senior Policy Adviser – Sustainable Finance, D.Avermaete@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.
Stay in touch with the EBF
The EBF produces a daily and a weekly newsletter with European banking news and updates from national banking associations across Europe. CLICK HERE TO SUBSCRIBE
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]]>PRESS RELEASE – FOR IMMEDIATE RELEASE
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.
Stay in touch with the EBF
The EBF produces a daily and a weekly newsletter with European banking news and updates from national banking associations across Europe. CLICK HERE TO SUBSCRIBE
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