EBA ESG Pillar 3 Disclosure Templates: What to Report From June 2026

ByOfficer

Last updated: May 2026

Get the ESG Pillar 3 disclosure wrong and you face two problems at once: a supervisory finding on your public report, and a data gap that cascades into your next ICAAP. The 30 June 2026 reference date is the next semi-annual disclosure point for large listed institutions already in scope. For institutions entering the expanded CRR3 perimeter, this disclosure cycle is the one your team should be building toward, even if the proportionate template detail depends on the amending ITS timeline still in progress.

I have seen reporting teams treat ESG disclosure as a sustainability function’s problem. It is not. The templates sit inside the Pillar 3 ITS. They follow the same sign-off governance as your COREP own funds or leverage ratio disclosures. If your disclosure control framework does not cover these templates yet, you are already behind.

This article covers the template structure, data requirements, proportionality tiers, and the practical traps that trip up teams filing ESG Pillar 3 disclosures for the first time or expanding their coverage under CRR3.

Related reading: Pillar 3 Disclosure Requirements for Luxembourg Banks

Legal Basis and Scope Under CRR3

Article 449a of Regulation (EU) No 575/2013 (CRR), as amended by Regulation (EU) 2024/1623 (CRR3), is the Level 1 mandate for ESG risk disclosures. The implementing vehicle is Commission Implementing Regulation (EU) 2024/3172 of 29 November 2024, which replaced the previous ITS under Implementing Regulation (EU) 2021/637. Article 22 of ITS 2024/3172 specifies the ESG disclosures, requiring institutions to disclose the Article 449a information set out in Section 21 of Annex I. The binding template instructions are published separately on the EBA website as part of the ITS IT solutions.

Before CRR3, only large institutions that had issued securities admitted to trading on a regulated market were in scope. Article 449a, introduced by CRR2 (Regulation (EU) 2019/876), brought these institutions into ESG disclosure under ITS that applied from 28 June 2022. The first disclosure reference date was 31 December 2022, annual for the first year, then semi-annual.

CRR3 expanded the scope to all institutions. References to Article 449a were inserted into Article 433a (large institutions), Article 433b (small and non-complex institutions), and Article 433c (other institutions). The amended Article 449a applies from 1 January 2025. Institutions newly brought into scope face annual disclosure with a first reference date of 31 December 2025, at a reduced template set, though the detailed proportionate templates are still being finalised through the amending ITS and enforcement in the interim is covered by the EBA no-action letter.

The EBA consultation paper EBA/CP/2025/07, published 22 May 2025, proposes the specific ITS amendments to implement this expanded scope. The full template set in Annex I applies to large listed institutions today. For institutions newly brought into scope, the Level 1 obligation under amended Article 449a already applies from 1 January 2025 (first reference date 31 December 2025, annual frequency); what remains pending is the proportionate template detail in the amending ITS, with enforcement covered by the EBA no-action letter in the interim.

EBA ESG Pillar 3 Disclosure Templates: The Full Set

Section 21 of Annex I to ITS 2024/3172 contains the complete ESG disclosure framework, with the binding instructions published on the EBA website as IT solutions. It breaks into three layers: qualitative tables, quantitative transition and physical risk templates, and mitigating-action templates.

Qualitative Tables (Tables 1, 2, and 3)

Table 1 covers qualitative information on environmental risk. Table 2 covers social risk. Table 3 covers governance risk. These are free-format text boxes where institutions describe their risk identification, measurement, management, and monitoring processes for each ESG risk category.

Teams commonly treat these as a copy-paste exercise from their annual report sustainability section. That is a mistake. The EBA instructions require disclosure of how ESG risks feed into your risk management framework specifically, not a general sustainability narrative. Supervisors read these qualitative sections alongside the quantitative templates and look for consistency.

Transition Risk Templates (Templates 1 to 4)

Template 1 presents banking book exposures by NACE sector, broken down by maturity bucket, showing gross carrying amounts alongside indicators of potential climate change transition risk. The sectoral breakdown follows EU Taxonomy-aligned NACE codes, with specific attention to carbon-intensive sectors. Financed emissions and scope 3 information sit within Template 1 at counterparty and portfolio level. Institutions that cannot yet estimate the scope 3 emissions of their counterparties must disclose their plans for implementing an estimation methodology.

Template 2 focuses on loans collateralised by immovable property, split by Energy Performance Certificate (EPC) label of the collateral. Columns capture gross carrying amount by EPC rating (A through G), plus a separate disclosure for exposures where no EPC information is available. Different Member States use different energy consumption thresholds for the same EPC labels. The instructions require institutions to explain this in the accompanying narrative.

Template 3 covers alignment metrics. It reports the institution’s portfolio alignment with Paris Agreement objectives by sector, using IEA Net Zero Emissions 2050 scenario metrics. Institutions disclose the alignment metric, the reference year, the distance to the 2030 IEA NZE2050 target in percentage terms, and their own three-year target. The sector breakdown follows a minimum list: power, fossil fuel combustion, automotive, aviation, maritime transport, cement/clinker/lime, iron and steel, chemicals, and others as relevant.

Template 4 discloses exposures to the top 20 carbon-intensive firms globally. It complements the sectoral approach with counterparty-level granularity, showing gross carrying amount, scope 1, 2, and 3 emissions of the counterparty, and the institution’s financed emissions attributed to each exposure.

Physical Risk Template (Template 5)

Template 5 captures exposures subject to physical climate risk, broken down by geography and sector. It distinguishes between chronic physical risk (gradual shifts like sea-level rise, temperature change) and acute physical risk (event-driven impacts like floods, storms, wildfires). Institutions map their exposures to geographic areas exposed to these hazards.

Mitigating Actions and Taxonomy Alignment (Templates 6 to 10)

Templates 6, 7, and 8 cover the Green Asset Ratio (GAR). Template 6 presents the summary GAR KPIs, Template 7 the assets used in the GAR calculation, and Template 8 the GAR itself. The GAR reports the proportion of the institution’s assets that finance Taxonomy-aligned activities. It depends directly on counterparty-level EU Taxonomy reporting data, which is why its practical implementation has been the most challenging for reporting teams. The frequency aligns with Article 8 of the Taxonomy Regulation Delegated Act.

Template 9 (9.1, 9.2, and 9.3) covers the Banking Book Taxonomy Alignment Ratio (BTAR). Unlike the GAR, which relies on published Taxonomy-alignment data from counterparties subject to sustainability reporting, the BTAR allows institutions to use estimates and proxies for counterparties that do not report. This makes it broader in scope but more methodologically demanding.

Template 10 covers other climate change mitigating actions not captured by the Taxonomy templates, including financed activities that contribute to climate change adaptation.

Proportionality: Three Tiers Under CRR3

The EBA designed three proportionality levels for the expanded scope under CRR3:

Large listed institutions disclose the full template set semi-annually. This is the baseline that has applied since 2022 and continues unchanged.

Other large institutions (non-listed) and large subsidiaries face a reduced template set. The EBA consultation EBA/CP/2025/07 proposes a proportionate approach where these institutions disclose essential quantitative templates without the full granularity required of listed peers.

Small and non-complex institutions (SNCIs) disclose only essential information on ESG risks. The EBA proposes this include physical and transition risk indicators and exposures to fossil fuel sectors, without the full GAR/BTAR templates or the alignment metrics. The exact template set for SNCIs is subject to the ongoing step 2 consultation.

A common governance failure I encounter: institutions that qualify as “other large” assume they can wait for the SNCI timeline. Check your classification under Article 4(1), point (146) CRR carefully. If you exceed any of the SNCI thresholds, you are in the “other institutions” tier at minimum, and potentially in the large-institution tier.

The Omnibus Complication

In August 2025, the EBA published Opinion EBA/Op/2025/11 (5 August 2025) in the form of a no-action letter. For the period from the 30 June 2025 reference date until the amending ITS enter into force, it recommends that competent authorities do not prioritise enforcement of Templates 6 to 10, Template 1 column c, and Template 4 column c (the Taxonomy and GAR-linked disclosures) for large listed institutions, and the corresponding templates for institutions newly brought into scope. The ECB has confirmed it will apply the same interim approach in its supervisory data collection. The Opinion responds to uncertainty created by the European Commission Omnibus Package, which proposed reforms to CSRD, CSDDD, and the EU Taxonomy.

The Omnibus Package matters for ESG Pillar 3 because several templates depend on counterparty Taxonomy reporting. If CSRD scope narrows or Taxonomy reporting obligations change, the data that feeds the GAR templates (6 to 8) and the BTAR template (9) becomes harder to source. The EBA noted that Pillar 3 requirements under the CRR operate independently of CSRD, but the practical data dependency remains.

The EBA’s consultation paper EBA/CP/2025/07 specifically addresses this by noting that Pillar 3 disclosure requirements do not exceed information included in the VSME standard as published by EFRAG, remaining within the value chain cap specified in the Omnibus proposal. This is the EBA’s attempt to keep ESG disclosures viable even under a reduced CSRD scope.

For reporting teams, the practical consequence is this: do not assume that Omnibus relief on CSRD reporting means relief on your Pillar 3 ESG disclosures. Article 449a CRR is a separate legal obligation. Even if your counterparties report less sustainability data under a reformed CSRD, your institution must still populate the Pillar 3 templates using whatever reasonable proxies and estimates are available.

Data Sourcing: Where Teams Struggle

The hardest operational challenge in ESG Pillar 3 disclosure is not the template layout. It is finding the data to fill it.

EPC Data for Template 2

Template 2 requires EPC labels for immovable property collateral. In practice, EPC coverage varies dramatically across EU Member States. Some national registries provide accessible databases. Others do not. Many mortgage portfolios contain collateral with no EPC on record, particularly for older properties or commercial real estate in jurisdictions where EPC requirements lag behind the EPBD recast timeline.

Institutions must disclose the share of exposures without EPC information separately. If that share is large, expect supervisory questions. Build a data remediation programme now rather than disclosing 40% “unknown” indefinitely.

Counterparty Emissions for Templates 1, 3, and 4

Scope 1 and 2 emissions data is increasingly available for large listed counterparties through CDP, annual reports, and ESG data vendors. Scope 3 remains patchy. The EBA instructions explicitly state that institutions not yet estimating scope 3 emissions of their counterparties must disclose plans for implementing estimation methodologies.

For Template 4 (top 20 carbon-intensive firms), the reference list changes annually. Ensure your data team monitors Carbon Majors or equivalent databases and updates the mapping each disclosure cycle.

Taxonomy Alignment for Templates 6 to 9

GAR data depends on counterparties subject to the NFRD/CSRD reporting their Taxonomy-eligible and Taxonomy-aligned activities. BTAR allows proxies for non-reporting counterparties. In practice, most institutions use a combination of reported data (where available) and sector-level estimates (where not).

The methodology for estimating BTAR must be disclosed in the narrative. Supervisors will compare your methodology description with the actual ratios reported. Unexplained divergences between GAR and BTAR trigger follow-up.

Governance and Sign-Off

ESG Pillar 3 disclosures sit within your disclosure control framework. They require the same governance as any other Pillar 3 template: data owner identification, four-eyes review, management body sign-off before publication, and audit trail documentation.

Where I see failures: sustainability teams produce the underlying data and analysis, then hand it to the reporting function as a finished product. The reporting function stamps it without challenge because they consider ESG “not their expertise.” This creates a control gap. Your disclosure policy must assign clear accountability for each template to someone in the reporting chain, not the sustainability chain.

The EBA expects institutions to describe their internal governance around ESG risk management in Table 1. If your qualitative disclosure describes a governance process that does not match how data actually flows into the quantitative templates, that inconsistency is visible to supervisors reviewing the complete Pillar 3 report.

Common Filing Errors

Based on the first three years of ESG Pillar 3 disclosures by large listed institutions, these patterns recur:

Mixing EPC labels across jurisdictions without explanation. A “B” rating in one Member State covers a different energy consumption range than a “B” in another. Template 2 instructions require the institution to explain this in the accompanying narrative. Most do not.

Reporting GAR based on revenue-alignment only, ignoring CapEx and OpEx alignment dimensions. The Taxonomy Regulation Delegated Act under Article 8 requires disclosure of all three KPIs. Omitting CapEx and OpEx alignment understates the ratio and creates an inconsistency with CSRD-reported figures from your corporate lending counterparties.

Using outdated IEA NZE2050 scenario data for Template 3 alignment metrics. The IEA updates its scenarios annually. Your alignment metrics must reference the most recent available scenario vintage, not the one you used two years ago.

Failing to reconcile aggregate sector exposures between Template 1 and your FINREP or large-exposure returns. The ESG templates use NACE sector codes. If your FINREP sector allocation differs from your ESG Pillar 3 sector allocation for the same portfolio, you will face questions. Ensure a single authoritative sector mapping feeds both.

Disclosing “zero” physical risk exposures when the institution has material real estate collateral in flood-prone areas. Supervisors cross-reference physical risk disclosures against known hazard maps. A zero disclosure implies either your assessment methodology is inadequate or your data is wrong.

Implementation Checklist for Mid-2026

For institutions with a 30 June 2026 reference date disclosure ahead of them, note first that the EBA no-action letter (EBA/Op/2025/11) means supervisors are not prioritising enforcement of Templates 6 to 10 and the Taxonomy-linked columns of Templates 1 and 4 until the amending ITS enter into force, so sequence your build accordingly:

Confirm your institution tier (large listed, other large, or SNCI) and the corresponding template set. Map each template to a data owner within your organisation.

Verify EPC data coverage for your immovable property collateral portfolio. Quantify the “no EPC available” share and establish whether it has improved since the last disclosure.

Update emissions data from counterparties. For Template 4, confirm the current top 20 carbon-intensive firms list against the latest available source and map exposures.

Review your Taxonomy alignment methodology for GAR and BTAR. Check whether any changes to counterparty CSRD reporting affect your data pipeline. Given the no-action letter, prioritise Templates 1 to 5 and defer Templates 6 to 10 build work if resources are constrained.

Update IEA NZE2050 scenario data for Template 3 alignment metrics. Document the scenario vintage in use.

Run a consistency check between ESG template sector allocations and FINREP/COREP sector classifications. Resolve mapping discrepancies before disclosure.

Draft qualitative Tables 1-3 early. Do not treat these as a last-minute exercise after the quantitative templates are filled. The qualitative narrative should inform and align with the quantitative data.

Schedule management body sign-off with sufficient lead time. ESG disclosures are published alongside the full Pillar 3 report and must follow the same approval process.

What Comes Next: Step 2 and Beyond

CRR3 extends scope to all institutions from 1 January 2025, with a first disclosure reference date of 31 December 2025 (annual frequency) for institutions newly brought into scope. The proportionate template detail is being finalised through the amending ITS (EBA/CP/2025/07), and enforcement in the interim is covered by the EBA no-action letter (EBA/Op/2025/11).

Separately, the interaction between the Omnibus Package and Taxonomy-dependent templates (GAR, BTAR) remains in flux. Institutions should build flexibility into their data sourcing architecture rather than committing to a single counterparty-data pipeline that may need restructuring if CSRD scope changes materially.

For institutions already disclosing, the focus for 2026 and 2027 should be data quality improvement, methodology stabilisation for scope 3 and BTAR estimates, and integration of ESG disclosure governance into the broader Pillar 3 control framework rather than treating it as a standalone sustainability exercise.

Frequently Asked Questions

Which institutions must disclose ESG Pillar 3 information today?

Large institutions that have issued securities admitted to trading on a regulated market in any EU Member State. This has applied since the first reference date of 31 December 2022 under Article 449a CRR. CRR3 extends scope to all institutions from 1 January 2025, with a first disclosure reference date of 31 December 2025 (annual frequency) for institutions newly brought into scope. The proportionate template detail is being finalised through the amending ITS (EBA/CP/2025/07), and enforcement in the interim is covered by the EBA no-action letter (EBA/Op/2025/11).

What is the disclosure frequency?

Semi-annual for large listed institutions. The first year of disclosure was annual; subsequent disclosures are semi-annual, with reference dates of 30 June and 31 December. For institutions newly brought into scope under CRR3, the first reference date is 31 December 2025 at annual frequency. Final frequency and template detail for each tier will be confirmed in the adopted amending ITS.

Where are the ESG templates published?

The templates are specified in Section 21 of Annex I to Commission Implementing Regulation (EU) 2024/3172. The EBA also makes the IT solutions (including instructions) available on its website under the Pillar 3 disclosures section.

Do SNCIs need to prepare now?

SNCIs should begin gap-analysis work even though the proportionate template detail is not yet finalised. The EBA consultation proposes a reduced template set focused on essential physical and transition risk indicators plus fossil fuel sector exposures. Data sourcing for even this reduced set takes time. Starting with an internal dry run ahead of the binding date is prudent. The EBA no-action letter covers enforcement in the interim for institutions newly brought into scope.

How does the Omnibus Package affect ESG Pillar 3 disclosure?

The Omnibus reforms to CSRD may reduce counterparty sustainability reporting, which indirectly affects data availability for the GAR (Templates 6 to 8) and BTAR (Template 9). However, Article 449a CRR operates independently. The Pillar 3 obligation remains regardless of CSRD scope changes. The EBA addressed this in its no-action letter EBA/Op/2025/11 (5 August 2025), recommending that supervisors not prioritise enforcement of Templates 6 to 10 and Taxonomy-linked columns of Templates 1 and 4 until the amending ITS enter into force. The ECB has confirmed it will apply the same interim approach.

What happens if I cannot source scope 3 emissions data?

The EBA instructions explicitly allow institutions that cannot yet estimate scope 3 to disclose their implementation plans instead. This is not a permanent exemption. Supervisors expect progressive improvement in data coverage each disclosure cycle. Document your methodology roadmap in the qualitative narrative.

Can I use estimates and proxies for the GAR and BTAR?

For the GAR (Templates 6 to 8), institutions should use actual Taxonomy-alignment data reported by counterparties subject to NFRD/CSRD. For the BTAR (Template 9), estimates and proxies are explicitly permitted for counterparties not subject to sustainability reporting. The methodology used for estimation must be disclosed and explained in the accompanying narrative.

How do I reconcile ESG sector exposures with FINREP?

Both ESG templates and FINREP use NACE sector codes, but at different levels of granularity. Build a single authoritative sector mapping that feeds both return types. Where ESG templates require finer sectoral breakdown (e.g., distinguishing fossil fuel subsectors), ensure those splits roll up correctly to the FINREP aggregation level. Document any mapping differences in your disclosure methodology.

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Key Takeaways

  • Article 449a CRR, implemented through Section 21 of Annex I to ITS 2024/3172, is the legal basis for ESG Pillar 3 disclosures. Large listed institutions have been disclosing semi-annually since the first reference date of 31 December 2022.
  • CRR3 extends ESG disclosure scope to all institutions from 1 January 2025. Institutions newly brought into scope have a first reference date of 31 December 2025 at annual frequency, with proportionate template detail being finalised in the amending ITS (EBA/CP/2025/07).
  • The EBA no-action letter (EBA/Op/2025/11) recommends supervisors not prioritise enforcement of Templates 6 to 10 and Taxonomy-linked columns of Templates 1 and 4 until the amending ITS enter into force. The ECB applies the same interim approach. Sequence your build accordingly.
  • The full template set covers qualitative tables (1-3), transition risk templates (1-4), a physical risk template (5), and mitigating action/Taxonomy templates (6-10).
  • Data sourcing is the primary operational challenge. EPC coverage, scope 3 emissions, and counterparty Taxonomy alignment data are the three hardest gaps to close.
  • The Omnibus Package may reduce CSRD counterparty reporting, but Article 449a CRR obligations remain independent. Build proxy and estimation methodologies as fallbacks.
  • ESG Pillar 3 requires the same governance and sign-off as any other Pillar 3 disclosure. Do not delegate to the sustainability function without integrating into the disclosure control framework.
  • Common errors include inconsistent sector mappings between ESG and FINREP, outdated IEA scenario vintages, incomplete EPC coverage disclosure, and qualitative narratives that contradict the quantitative data.

Sources and References

  • Regulation (EU) No 575/2013 (CRR), Article 449a, as amended by Regulation (EU) 2024/1623 (CRR3) – EUR-Lex
  • Commission Implementing Regulation (EU) 2024/3172 of 29 November 2024 (Pillar 3 ITS replacing 2021/637) – EUR-Lex
  • EBA Pillar 3 ITS page and IT solutions (instructions) – EBA
  • EBA Consultation Paper EBA/CP/2025/07, 22 May 2025, Draft ITS amending ITS 2024/3172 on ESG risk disclosures – EBA
  • EBA Opinion EBA/Op/2025/11, 5 August 2025, No-action letter on the application of provisions relating to disclosures on ESG risks – EBA
  • ECB FAQs on the application of ESG disclosure requirements following the EBA no-action letter – ECB Banking Supervision
  • EBA Final Report EBA/ITS/2022/01, 24 January 2022, Final draft ITS on prudential disclosures on ESG risks in accordance with Article 449a CRR – EBA
  • Regulation (EU) 2024/1623 (CRR3) – EUR-Lex

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.

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