Our Response to the EBA Consultation on the Amendment of its Pillar 3 Reporting

On May 22, 2025, the European Banking Authority (EBA) launched a consultation regarding the amendment of implementing technical standards (ITS) for Pillar 3 reporting, to which credit institutions operating in the European Union are subject. These amendments follow particularly the implementation of CRR3 in January 2025, which strengthens and introduces proportionality measures in bank disclosure requirements.

Presentation of the Consultation

The consultation on amended publication requirements concerning ESG risks, equity exposures, and aggregate exposure to shadow banking entities was opened by the EBA on May 22 and closed on August 22, 2025. It consisted of 33 questions in total, of which 28 concerned ESG risks and 5 concerned exposures. The majority of questions were open-ended, inviting us to provide our comments and suggestions on the changes made to the reporting. As ESG is our core business, we exclusively considered questions related to this subject in our response.

Regarding Next Steps:

• The EBA published a no-action letter on August 11, 2025, inviting regulators not to prioritize the application of new ESG reporting requirements under Pillar 3 for banks, initiating the transition phase provided for in the consultation.
• Depending on the provisions adopted in the text submitted for consultation, large listed institutions, already subject to the standard, could continue to publish their EBA P3 report with the exception of information concerning Taxonomy regulation and the Green Asset Ratio (GAR). These latter elements are likely to come into force at the same time as the amended version of the text on December 31, 2026.
• For other listed or non-listed institutions and large subsidiaries falling within the scope of the regulation, publication should begin on December 31, 2026.

Our Response

WeeFin welcomes the general direction adopted by the reporting tables and templates submitted for consultation, which represents a positive and pragmatic advance in the evolution of the ESG disclosure framework of Pillar 3.

Overall, the proposed measures can improve the requirements and quality of reporting while limiting duplicates and low-value data points. They also introduce relevant proportionality measures, related to the size and complexity of banking institutions. Furthermore, the proposals ensure that the ESG information communicated contributes to the objective of facilitating prudential supervision and informed investment decisions.

• Harmonization: WeeFin welcomes the harmonization efforts with other standards (Taxonomy, CSRD) and frameworks (PCAF, SBTi FINZS) proposed by the EBA. The improvement of interoperability between CSRD ESRS, EU Taxonomy, and EBA P3 reporting models is particularly relevant, as it helps reduce the reporting burden and inconsistencies between regulatory requirements, promoting the harmonization of concepts and definitions used at the EU level.
  

• Proportionality and Reduction of Reporting Burden: The data to be reported in the modified templates are complete and of quality. In addition, these modifications introduce simplified mandatory reporting for other listed institutions and large subsidiaries.
  

• Better Reporting of Physical Risks: The special attention given to physical risks, particularly their breakdown by risk type and geographical area, is very important. Integrating these concepts into other dimensions of ESG risk management will require dedicated time and resources.

Some Attention Points:

While favorable to these proposals, WeeFin considers that several elements require additional safeguards to ensure the effectiveness of the framework and guarantee its long-term operational viability:

• The reliability of ESG publications depends on the robustness of data governance frameworks. This includes clear requirements on data traceability, documentation of data sources, validation processes, and auditability mechanisms. WeeFin recommends that the final framework strengthen these aspects to mitigate the risk of inconsistent or unverifiable reporting.
  

• The EBA should also take into account the issues of availability and quality of ESG data, which still exist today. The P3 reporting templates require institutions to publish accurate and complete data, which can sometimes be complex to collect. Thus, WeeFin suggests two areas for consideration:
  
  • The burden of producing complete and quality data should rest on companies, public institutions, and financial companies alike. This data can only exist through cooperation between the various stakeholders, via granular reporting standards and/or by highlighting dedicated public resources.
  • Once the data is published by the various stakeholders, quality indicators could be applied to the reported information to highlight data reliability. These indicators could, for example, be as follows: primary data, PCAF methodology, uncertainty percentages, estimates, etc.
    

• ESG metrics must be calculated and disclosed consistently in order to serve their market transparency and supervision objectives. In this regard, WeeFin believes that the requirement to publish the GAR should not be postponed until the end of 2026, and that mandatory disclosure of the Banking Taxonomy Alignment Ratio (BTAR) should be considered. This would enhance the efforts made by institutions to align with the taxonomy regulation and calculate their alignment before the opening of debates related to Omnibus I, while ensuring that reliable, comparable, and standardized metrics are available across the banking sector.
  

• Finally, some proposed requirements, such as geographical breakdowns at NUTS-3 level, are likely to represent a major operational challenge for banking actors, particularly for cross-border institutions with complex portfolios. WeeFin suggests reassessing granularity thresholds to find a balance between precision and feasibility, and to avoid diverting resources from the quality and analytical value of disclosures.

With targeted adjustments in these areas, the final ESG disclosure framework of Pillar 3 would not only improve its relevance but would also support sustainable and proportionate implementation across the banking sector.

To consult our complete response, click here.