Stockholm (NordSIP) – The European Banking Authority (EBA) has issued a “no-action” letter to national supervisors advising them not to prioritise enforcement of certain ESG disclosure obligations defined in the last two years.
This temporary measure, published on August 6, 2025, comes amid regulatory uncertainty triggered by the European Commission’s broader efforts to streamline EU sustainability legislation through the so-called “Omnibus” package.
ESG Disclosures to be Ignored
The “no-action” recommendation refers mainly to two sets of ESG disclosure requirements that are to be ignored for the time being.
First, national regulators are to not prioritise the enforcement of the disclosure of certain ESG disclosure templates (notably EU 6 to EU 10, and specific columns in Templates 1 and 4) of the Commission’s Implementing Technical Standards (ITS) Regulation (EU 2024/3172) of November 2024, updating the public disclosures rules under the 2013 Capital Requirements Regulation (CRR)¹.
Second, national regulators should not prioritise the enforcement of the collection of templates EU 6 to 10, and specific columns in Templates 1 and 4 of the EBA Decision EBA/DC/498 of 6 July 2023, for large institutions with listed securities.
¹ The EU’s CRR implements the Basel III framework of global banking regulation rules, devised in the aftermath of the financial crisis of 2007-2008. The ITS pertinent to this “no-action” refers to disclosures based on Basel III’s Pillar 3, which seeks to promote market discipline through regulatory disclosure requirements. As implemented by the EU’s Pillar 3, and interpreted by the EBA’s Pillar III, CRR Article 449a include ESG disclosures.
