02 June 2021

EBA consultation on draft technical standards on Pillar 3 disclosures of ESG risks: EBF response

• 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 availability of relevant and reliable data. A meaningful reporting to supervisors / survey should be explored until robust methodologies for banks are developed at 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.

Full paper

EBF

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