EBA Proposes Proportionate ESG Reporting for Banks

Supervisory ESG reporting is moving closer to the centre of the EU prudential reporting framework for banks. The latest EBA package links a new ESG reporting module to a broader effort to simplify reporting, reduce data demands and reshape how supervisors collect risk information.

The European Banking Authority (EBA) has opened a consultation on a broad revision of EU supervisory reporting, including a proposed ESG reporting module within the revised Implementing Technical Standards (ITS) on supervisory reporting and a wider simplification package. The package places prudential ESG reporting under the Capital Requirements Regulation (CRR) within a broader redesign of supervisory reporting around proportionality, frequency and data re-use.

The EBA says the package would reduce data points in the EU harmonised reporting framework by around 50%, despite new requirements linked to IFRS 18, ESG and the Fundamental Review of the Trading Book (FRTB).

What Is Being Proposed

The legal base is Regulation (EU) No 575/2013, the CRR, which mandates the EBA to develop implementing technical standards for uniform supervisory reporting. The current framework is set out in Commission Implementing Regulation (EU) 2024/3117. The April 2026 consultation proposes revisions to that framework, including the addition of ESG reporting.

The package combines regulatory amendments with simplification measures. It covers IFRS 18-related FINREP changes, market risk, operational risk, liquidity, asset encumbrance, stress-testing data and alignment with Pillar 3 disclosures for small and non-complex institutions.

ESG reporting is one of the modules explicitly listed in the consultation package. In the draft ITS, it takes legal form through proposed Article 21c on reporting on exposures to ESG risk on an individual and consolidated basis.

In parallel, the EBA has opened a separate consultation on revised supervisory benchmarking ITS for credit risk and IFRS 9. This benchmarking consultation sits alongside the wider effort to simplify benchmarking templates and integrate them into the supervisory reporting framework from 2027.

Status and Enforceability

Responses are due by 10 July 2026, with an earlier 10 May 2026 deadline for certain IFRS 18-related FINREP templates. The consultation package is also accompanied by public hearings and a workshop on reporting simplification.

Until adoption, the binding framework remains Commission Implementing Regulation (EU) 2024/3117. The draft regulation states an application date of 28 September 2027, and the consultation paper says first reporting is expected for the reference date of 30 September 2027.

Draft Article 21a would allow small and non-complex institutions to report the fuller set required for larger firms and allow mid-tier institutions to opt into the large-institution set.

Scope and Timeline

The ESG reporting proposal is explicitly tiered. Large institutions would report a broader set of ESG risk exposure templates, with some templates reported semi-annually and others annually. Large institutions with total assets above EUR 30 billion would report a fuller version of that package.

Other listed institutions would report a narrower annual set. Large subsidiaries would also report annually, on an individual or, where relevant, sub-consolidated basis. Small and non-complex institutions and other non-listed institutions would report only template D 01.01 annually at the highest level of consolidation in the Union.

That tiered design reflects the wider simplification logic: the more complex the institution, the broader the reporting set. Across the wider package, simplification is to be delivered through fewer data points and templates, adjusted reporting frequency and scope, greater proportionality for small and non-complex institutions, broader use of a core-plus-supplement approach, and stronger use of integrated data collections.

Why ESG Sits Inside Prudential Reporting

The consultation paper says CRR extends reporting and disclosure so that competent authorities have harmonised data to assess institutions’ exposures to environmental and climate-related risks and their risk mitigation strategies. In that sense, the proposal places ESG data more firmly inside prudential supervision while redesigning the broader reporting perimeter at the same time.

The EBA is trying to reduce reporting cost without removing supervisory use, and the paper presents ESG reporting as one module within that broader restructuring. The agenda also extends beyond the EU harmonised framework: the EBA plans to develop a public EU-wide repository of data requests and, as a first step in this package, has published an overview of national supervisory data collections and ongoing simplification efforts by competent authorities.

What to Watch Next

The EBA plans to submit the final report to the European Commission by the end of 2026, with first reporting expected for 30 September 2027. Until then, the proposal remains open and its final shape depends on consultation feedback.

The next points to watch are the final tiering by institution type, the detailed instructions and technical package behind the ESG templates, and how the EBA translates simplification into reporting requirements that remain consistent with supervisory timelines.

The broader direction is clear. The package points to a more selective supervisory reporting architecture, not a retreat from ESG risk reporting. The open question is how far the final ITS can turn simplification and proportionality into a framework supported by workable templates, definitions and technical specifications.