CRR3 Pillar 3 disclosure update: what EBA’s ESG, equity and shadow-banking changes mean for your next disclosure cycle

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Keywords: CRR3 Pillar 3 disclosure, EBA ESG disclosure ITS, Article 449a, aggregate exposure to shadow banking entities, equity exposures disclosure, EU SB1 template

Selected Title: CRR3 Pillar 3 disclosure update: what EBA’s ESG, equity and shadow-banking changes mean for your next disclosure cycle

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Category: Prudential Reporting

Slug: crr3-pillar-3-disclosure-esg-equity-shadow-banking-eba-its

Description: EBA’s June 2026 ITS rewrites CRR3 Pillar 3 disclosure for ESG risks, equity and shadow banking. Reference dates, deleted templates and the new EU SB1.

Jurisdictions: EU

Last updated: June 2026

The trap in this round of CRR3 Pillar 3 disclosure changes is the templates that vanished, not the new template. A reporting team that builds its 31 December 2026 disclosure off last year’s mapping will still be populating the Green Asset Ratio tables, still chasing top-20 carbon-intensive counterparty data, and still wiring cross-references to the Taxonomy delegated act. None of that survives. On 22 June 2026 the EBA published its final draft Implementing Technical Standards (EBA/ITS/2026/02) amending the Pillar 3 framework, and it deletes five ESG templates, rewrites the equity exposure template, and adds an entirely new shadow-banking disclosure. If your build plan treats this as an incremental refresh, you will report the wrong thing on time, which is a worse outcome than reporting the right thing slightly late.

Three CRR3 changes converge in one ITS. The disclosure of environmental, social and governance risks under Article 449a is rebuilt and extended to far more institutions. The equity exposures disclosure under Article 438(e) is simplified to a single total. And a new Article 449b disclosure on the aggregate exposure to shadow banking entities arrives with its own template, EU SB1. Each carries a different reference date and a different scope of institutions, and the EBA has woven proportionality through all three so that what a small bank discloses bears little resemblance to what a large listed group discloses.

This is a change note, not a first-principles guide to Pillar 3. If you need the foundations, start with our Pillar 3 disclosure requirements guide and come back. What follows maps the deltas: what the regulation now requires, which templates change, when each applies, and the places teams are most likely to get it wrong.

Related reading: EBA ESG Pillar 3 Disclosure Templates: What to Report

The legal chain: where these CRR3 Pillar 3 disclosure changes come from

The Level 1 driver is Regulation (EU) 2024/1623, adopted on 31 May 2024 and published in the Official Journal on 19 June 2024, which amends the Capital Requirements Regulation (Regulation (EU) No 575/2013) and is now referred to as CRR3. CRR3 did three things to Part Eight disclosure that this ITS implements. It replaced Article 449a with modified ESG disclosure requirements and an extended scope. It amended Article 438(e) on equity exposures. And it inserted a new Article 449b requiring institutions to disclose their aggregate exposure to shadow banking entities.

None of those Level 1 obligations work on their own. Article 449a expressly links to Article 434a and mandates the EBA to develop implementing technical standards specifying the disclosure formats. So the binding detail, the templates, the tables, the instructions, lives one layer down in the EBA ITS rather than in the regulation itself. That is why the 22 June 2026 final report matters operationally: it is the document that tells you what cell to populate.

The ITS does not stand up a new instrument. It amends Commission Implementing Regulation (EU) 2024/3172, which is the current consolidated Pillar 3 ITS. A recurring error in articles written about this area is to reach for the older Implementing Regulation (EU) 2021/637 or the 2022 ESG ITS (Implementing Regulation (EU) 2022/2453). Both are historical. The 2022 ESG ITS amended 2021/637, and 2021/637 was repealed and replaced by 2024/3172. The 22 June 2026 EBA final draft ITS (EBA/ITS/2026/02) is the EBA final draft amending Commission Implementing Regulation (EU) 2024/3172; for binding disclosures, cite the adopted Commission amending act once published, not the superseded 2021/637 or 2022/2453.

One date is easy to misstate. CRR3 was adopted on 31 May 2024, published in the Official Journal on 19 June 2024, and entered into force on 9 July 2024, applying from 1 January 2025. For the amending Pillar 3 ITS, use the adopted Commission Implementing Regulation and Official Journal citation once available; the disclosure build should be anchored to the first reference dates, not to a draft application date. These are not the same date, and the ITS application date is distinct again from the disclosure reference dates discussed below. Keep the three apart in your documentation.

ESG disclosure scope widens: who has to disclose under Article 449a now

Under the framework in force until this amendment, prudential ESG disclosure under Article 449a sat with large institutions that have issued securities admitted to trading on a regulated market of a Member State. CRR3 extends Pillar 3 ESG disclosures to all institutions, well beyond that large-listed population, and tells the EBA to implement the extension proportionately. The EBA chose a three-tier design rather than a two-tier one. That choice is the single most important thing for scoping your obligation.

The three tiers, expressed in the amended Article 22 of 2024/3172, map to the CRR’s own level-of-application articles:

Large institutions subject to Article 433a disclose the comprehensive set, using the templates in Part 1 of Section 21 of Annex I. Other listed institutions subject to Article 433c(1), and large subsidiaries subject to Article 13(1) second subparagraph, disclose a simplified set using the templates in Part 2 of Section 21, with carve-outs from certain qualitative tables. Small and non-complex institutions (SNCIs) subject to Article 433b, and other non-listed institutions subject to Article 433c(2), disclose the most basic set using Part 3 of Section 21.

The proportionality cuts deeper than template count. The EBA amended the framework so SNCIs report only quantitative information; qualitative disclosures are no longer mandatory for them, and Table 1A in particular does not apply to SNCIs. Large subsidiaries are also relieved of qualitative information, on the logic that the narrative is already disclosed at consolidated level. Where teams trip up is assuming the simplified set is simply the large-institution set with rows hidden. It is not. The Part 2 and Part 3 template populations differ in substance, and the EBA built them as distinct sets precisely so smaller institutions are not forced through large-institution logic.

Frequency is governed by the CRR, not by the EBA’s preference. Article 433a sets semi-annual disclosure of Article 449a information for large listed institutions. The EBA could not change that, but it did open a materiality-based route to annual disclosure for items that are stable over the period, citing Article 432 of the CRR, which allows omission of immaterial information. Qualitative tables and the targets template are the natural candidates, because policies and emission targets are set annually. This is a permission, not an automatic reduction. An institution that wants to disclose those items annually has to be able to defend the materiality judgment, not just assert it.

What changed inside the ESG templates: deletions, not additions

The headline for large institutions is that this is mostly a simplification, not a new data ask. The EBA’s own framing is that there are no new requirements for large institutions, only enhanced clarity built from the Questions and Answers it received on the framework in place. The substantive movement is in what came out.

Template 4, the banking-book transition-risk template on exposures to the top 20 carbon-intensive firms, is deleted. Respondents argued it captured a very small portion of exposures, relied on divergent third-party reference lists with no single authoritative source, and overlapped with Template 1. The EBA agreed and removed it. Concentration risk of this kind, in the EBA’s view, is better picked up through supervisory reporting than through Pillar 3.

Templates 6 to 9, covering the Green Asset Ratio and the Banking Book Taxonomy Alignment Ratio, are also removed. The reasoning is the report-once principle plus the shrinking relevance of taxonomy-aligned exposure data: with the CSRD and Taxonomy Regulation under review and their scope reduced, a large share of banks’ counterparties will fall outside the Taxonomy and outside the GAR. Rather than maintain duplicative tables, the EBA cut them. This is the change most likely to break an existing data pipeline, because GAR production typically involves a dedicated workstream that now has no Pillar 3 home.

Template 10, on mitigating actions, survives but is rescoped. With the GAR templates gone, the EBA broadened Template 10 so institutions disclose all exposures that mitigate climate-related risks regardless of taxonomy alignment, including investments contributing to climate change mitigation, adaptation and other environmental objectives such as nature and biodiversity protection. The template now spans both transition and physical risk, broken down by instrument and counterparty. If you previously treated Template 10 as the taxonomy-adjacent residual, that mental model no longer fits.

Two more points that are easy to get wrong. Template 1.1 is retained, not deleted, for SNCIs and other non-listed institutions; the EBA streamlined it to combine transition and physical risk in a single minimum view but kept it as the floor of climate transparency. And the geographical granularity for physical risk in Template 5 shifted from a top-10 NUTS level 3 breakdown to a country-based breakdown, with institutions still expected to assess at the highest granularity available, at least NUTS level 3, where finer data exists. Do not carry the old NUTS-3 disclosure format forward unchanged.

The no-action letter is doing transitional work, and it is not the ITS

There is a sequencing point that has caused real confusion this cycle. In August 2025 the EBA published a no-action letter clarifying the application of Templates 6 to 10 and certain columns in Templates 1 and 4 during the period before the amending ITS took effect. That letter was a pragmatic bridge over the legal uncertainty created by the parallel review of the ESG framework and the CSRD “Stop the Clock” timeline. It is not the binding standard.

The Banking Stakeholder Group made the right structural point about this: a no-action letter is a supervisory forbearance device, and where timing, adjustments or clarifications are needed they should ideally come through formal legislative or regulatory channels rather than non-binding guidance. The practical takeaway for a reporting team is to keep the two instruments cleanly separated in your control framework. The no-action letter governs the interim. From the 31 December 2026 reference date, the amending ITS governs, Templates 6 to 9 are gone for good, and institutions are expected to disclose in accordance with the ITS. Do not let a build that was scoped around the no-action letter quietly become your go-live build. For how the same proportionality logic is shaping supervisory reporting for smaller banks, see our note on the EBA Pillar 3 data hub for smaller banks and SNCIs.

Equity exposures: Article 438(e) becomes a single total

The equity change is small in volume and large in principle. CRR3, implementing the Basel standards, removed the ability to use the Internal Ratings Based approach for equity exposures except during the transitional period in Article 495(1). Following that, Article 438(e) was amended to align the disclosure with the standardised-approach treatment of equity in Article 133(3) to (6) and the transitional provisions of Article 495a(3).

The EBA’s implementation choice was to keep this as simple as the Level 1 text allows. The amended template EU CR 10.5, which sits in Section 12 on specialised lending and equity exposures, now requires only the total amount of equity exposures. Respondents had asked whether amounts should be broken down by category of equity exposure; the EBA clarified in the instructions that only the total is required, with no breakdown by category, because the breakdown is not strictly provided for by CRR3.

Two operational notes. The scope of the equity disclosure did not change with CRR3. Article 438 disclosure applies to large institutions and other listed institutions, not to non-listed SNCIs, and the EBA confirmed this against Articles 433, 433a, 433b, 433c and 434. So the simplification does not pull new institutions into equity disclosure. And because the disclosure obligation under Article 438(e) is already applicable, the EBA kept the first application date of the new EU CR 10.5 template flexible: institutions may choose to adopt the simplified template earlier than the 31 December 2026 reference date if they want the benefit of the lighter format sooner. That flexibility is unusual and worth flagging to whoever owns your disclosure calendar.

The new disclosure: aggregate exposure to shadow banking entities under Article 449b

This is the genuinely new build. Article 449b is inserted by CRR3 and requires institutions to disclose information concerning their aggregate exposure to shadow banking entities, cross-referring to Article 394(2) second subparagraph. There is no Basel disclosure standard for this, so the EBA designed the template from scratch. It is EU SB1, and it lives in a new Section 23 of Annex I, introduced by a new Article 23a of 2024/3172.

What counts as a shadow banking entity is set elsewhere and you inherit it, not a Pillar 3 question. The definition moved from Article 394(2) of CRR2 into Article 4(1)(155) of CRR3. The identification criteria are in the regulatory technical standards adopted as Commission Delegated Regulation (EU) 2023/2779 of 6 September 2023. In broad terms, an entity that performs banking-type activities without being authorised and supervised under one of the Union acts listed in the annex to those RTS is a shadow banking entity, and certain exposures are treated as such by default, including exposures to money market funds and to alternative investment funds that employ substantial leverage, originate loans in the ordinary course of business, or buy third-party lending exposures for their own account.

The template content was deliberately kept lean. The EBA considered a breakdown by counterparty type but chose to require only the aggregate exposure, because a counterparty breakdown could go beyond Article 449b and the framework is about to move again under the new Article 395(2a) mandate. EU SB1 captures original exposures for both on-balance-sheet and off-balance-sheet items, plus exposure values before and after the exemptions in Articles 400 and 493(3) and credit risk mitigation, mirroring the information already required in the supervisory reporting template LE3. If your team already produces the large-exposures returns, the source data for EU SB1 largely exists; the work is plumbing it into a disclosure rather than sourcing it fresh. Our large exposures reporting guide covers the LE template family that feeds it.

The first reference date for EU SB1 depends on institution type. Institutions subject to Article 433b(1)(f) are expected to start from the 31 December 2027 reference date. Other in-scope institutions should plan on the 31 December 2026 reference date, subject to the final Commission Implementing Regulation as adopted and published in the Official Journal. This sits alongside a deliberate split between disclosure and supervisory reporting: the new supervisory reporting template for aggregate shadow-banking exposures, C 37.00, was postponed into the CRR3/CRD6 step 2 reporting package, with that consultation expected by Q1 2026 and a first application date around September 2027. So disclosure and reporting on shadow banking are intentionally not synchronised in their first reference dates, and a plan that assumes a single shadow-banking go-live will misfire.

Reference dates: the part you cannot afford to read loosely

The dates are where a confident-sounding plan goes wrong, so here they are laid out by obligation rather than by template.

For ESG disclosures under Article 449a, the general first reference date is 31 December 2026. For SNCIs, the first reference date is 31 December 2027. The EBA pushed the SNCI date out specifically to align with the Pillar 3 Data Hub timeline and to give smaller institutions time to prepare. For the equity template EU CR 10.5, the reference date is 31 December 2026, but earlier voluntary adoption is permitted because the underlying Article 438(e) obligation already applies. For the shadow-banking template EU SB1, institutions subject to Article 433b(1)(f) are expected to have a first reference date of 31 December 2027; other in-scope institutions should plan on the 31 December 2026 reference date, subject to the final Commission Implementing Regulation as adopted and published in the Official Journal. The amending ITS will enter into force and apply as set out in the Commission Implementing Regulation once adopted and published in the Official Journal; operational planning should track the disclosure reference dates separately from the instrument’s legal application date.

The trap here is treating “the ITS applies from 1 December 2026” as the date you must disclose. It is not. The application date of the instrument and the reference date of a disclosure are different concepts, and the reference date is the one that tells you which balance-sheet snapshot you report and when the disclosure is due. For the difference between entry into force, application and reference dates across the wider CRR3 package, our CRR3 output floor phase-in note works through the same date discipline on a related topic.

The minor template changes that still need a code change

Beyond the three headline areas, the ITS replaces several templates that teams may not be watching. Template EU CQ5 in Section 8, on the credit quality of loans and advances to non-financial corporations by industry, is replaced to reflect the new NACE classification, NACE Rev. 2.1, which is already applicable. The ITS also replaces EU CMS2 in the overview-of-risk-management section, EU LIQ2 in the liquidity-requirements section, and EU CVA2 in the credit-valuation-adjustment section, each in a separate annex.

None of these are large in disclosure terms, but the NACE Rev. 2.1 change in EU CQ5 is the kind of thing that silently breaks validations if the mapping is stale. If your industry-sector breakdown still runs on the prior NACE revision, the figures may footing-tie and still be wrong at the sector level. The EBA also clarified the application of the credit-risk templates to listed SNCIs and other non-listed institutions under Articles 433b and 433c, which is a scoping clarification rather than a new template, but one that affects which credit-risk tables those institutions actually owe.

The Pillar 3 Data Hub changes who produces some of this

The mechanism that makes the SNCI extension workable is the Pillar 3 Data Hub. The EBA’s stated next step after publication is to submit the final draft ITS to the Commission and to develop the data point model and the XBRL taxonomy for implementation within the data hub, with an updated mapping tool against supervisory reporting expected during 2026. For SNCIs, the intent is that the EBA centrally pre-fills and discloses ESG information based on supervisory reporting, which is why the SNCI reference date and the data hub timeline were aligned.

That changes the operating model for smaller institutions in a way that is easy to under-appreciate. An SNCI’s ESG disclosure obligation is being met, in part, through data it already submits to its competent authority, re-presented by the EBA, rather than through a separately produced public report. The control implication is that data quality in supervisory reporting becomes the disclosure control: an error in the submission becomes an error in the published disclosure. For how the DPM and XBRL mechanics move in the wider framework releases, see our walkthrough of the EBA framework 4.3 DPM changes for COREP and FINREP.

Frequently Asked Questions

Is the 22 June 2026 EBA publication final and binding yet?

It is a final draft ITS (EBA/ITS/2026/02). The EBA’s next step is to submit it to the European Commission for adoption. The binding Commission Implementing Regulation amending 2024/3172 follows once adopted and published in the Official Journal. The drafted application date is 1 December 2026, but you should confirm the adopted instrument’s Official Journal citation before treating the date as fixed.

Which instrument do I actually cite for 2026 Pillar 3 disclosures?

Commission Implementing Regulation (EU) 2024/3172, as amended by the Commission Implementing Regulation adopted from the EBA final draft ITS once it is published in the Official Journal. Until then, cite EBA/ITS/2026/02 as the EBA final draft reference only. Do not cite Implementing Regulation (EU) 2021/637 or the 2022 ESG ITS (Implementing Regulation (EU) 2022/2453); both were superseded. 2024/3172 is the current consolidated Pillar 3 ITS.

Do small and non-complex institutions have to disclose ESG information now?

CRR3 extends Article 449a ESG disclosure to SNCIs, but the first reference date for SNCIs is 31 December 2027, not 2026. SNCIs disclose only quantitative information using the basic set in Part 3 of Section 21; qualitative disclosures, including Table 1A, are not mandatory for them. The EBA intends to pre-fill SNCI ESG information centrally through the Pillar 3 Data Hub based on supervisory reporting.

What happened to the Green Asset Ratio templates?

Templates 6 to 9, covering the GAR and BTAR, are removed from the final ITS to avoid duplication with the Taxonomy Regulation and CSRD and because a shrinking share of counterparties falls within Taxonomy scope. Template 4, on top-20 carbon-intensive firms, is also deleted. Template 10 survives but is rescoped to cover all climate-risk-mitigating exposures regardless of taxonomy alignment.

When does the new shadow-banking disclosure start?

The aggregate exposure to shadow banking entities under Article 449b is disclosed using the new template EU SB1. Institutions subject to Article 433b(1)(f) are expected to have a first reference date of 31 December 2027; other in-scope institutions should plan on the 31 December 2026 reference date, subject to the final adopted Commission text. The matching supervisory reporting template, C 37.00, was postponed to the CRR3/CRD6 step 2 reporting package, expected to apply around September 2027.

How do I identify a shadow banking entity for the new disclosure?

The definition is in Article 4(1)(155) of CRR3, and the identification criteria are in Commission Delegated Regulation (EU) 2023/2779. Money market funds and highly leveraged or loan-originating alternative investment funds are treated as shadow banking entities by default. The EU SB1 data largely overlaps with what feeds the LE3 large-exposures reporting template.

Can large institutions reduce disclosure frequency to annual?

The CRR sets semi-annual disclosure for large listed institutions under Article 433a, and the EBA cannot override that. The EBA did confirm that, under the materiality principle in Article 432, institutions may disclose stable items such as qualitative tables and the targets template annually where repeating them more frequently would be immaterial. That is a defensible materiality judgment, not an automatic reduction.

Related Articles

Key Takeaways

  • The 22 June 2026 EBA final draft ITS (EBA/ITS/2026/02) is the EBA final draft amending Commission Implementing Regulation (EU) 2024/3172; for binding disclosures, cite the adopted Commission amending act once published, not the superseded 2021/637 or 2022/2453.
  • ESG disclosure under Article 449a is rebuilt as three tiers (large; other listed plus large subsidiaries; SNCI and other non-listed) with distinct template sets, not a single set with rows hidden.
  • Templates 4 and 6 to 9 are deleted, Template 10 is rescoped to all climate-risk-mitigating exposures, and Template 1.1 is retained as the SNCI minimum.
  • The new EU SB1 template implements the Article 449b aggregate shadow-banking disclosure; institutions subject to Article 433b(1)(f) are expected to start from the 31 December 2027 reference date, while other in-scope institutions should plan on the 31 December 2026 reference date, subject to the final adopted Commission text. EU SB1 reuses LE3-style data.
  • Equity disclosure under Article 438(e) collapses to a single total in the amended EU CR 10.5, with voluntary early adoption permitted.
  • General ESG reference date is 31 December 2026; SNCIs and Article 433b(1)(f) institutions start 31 December 2027; the amending ITS will apply as set out in the Commission Implementing Regulation once adopted and published in the Official Journal, which is not a disclosure date.
  • The August 2025 no-action letter is interim forbearance only; the ITS governs from the 31 December 2026 reference date.
  • EU CQ5 moves to NACE Rev. 2.1, and EU CMS2, EU LIQ2 and EU CVA2 are also replaced; stale NACE mappings will pass footing checks while still being wrong.

Sources and References

  • EBA, “EBA updates Pillar 3 disclosure requirements on ESG risks, equity and shadow banking exposures, as part of simplification effort”, press release, 22 June 2026 – eba.europa.eu
  • EBA, Final Report, Draft ITS amending Commission Implementing Regulation (EU) 2024/3172 as regards the disclosures on ESG risks, equity exposures and the aggregate exposure to shadow banking entities (EBA/ITS/2026/02, 22 June 2026) – Final Report (PDF)
  • Regulation (EU) 2024/1623 (CRR3) amending Regulation (EU) No 575/2013, including Articles 438(e), 449a and 449b – EUR-Lex CELEX 32024R1623
  • Commission Implementing Regulation (EU) 2024/3172 laying down ITS for Pillar 3 disclosures – EUR-Lex CELEX 32024R3172
  • Commission Delegated Regulation (EU) 2023/2779 of 6 September 2023, RTS on criteria for the identification of shadow banking entities under Article 394(2) CRR – EUR-Lex CELEX 32023R2779
  • EBA Guidelines EBA/GL/2015/20 on limits on exposures to shadow banking entities (to be updated under Article 395(2a) CRR3) – eba.europa.eu
  • EBA Consultation Paper EBA/CP/2025/07 on the draft amending ITS (basis for this final report) – eba.europa.eu

What to lock in before your next disclosure build freezes

Treat this as a scoping exercise before a coding exercise. Confirm which of the three ESG tiers your institution falls into under Articles 433a, 433b and 433c, because the template set follows from that, and the SNCI route comes with a 2027 reference date and central pre-filling rather than a 2026 build. Decommission the GAR and top-20 carbon workstreams from the Pillar 3 pipeline, but only after you have confirmed where, if anywhere, that data still lands under CSRD. Stand up the EU SB1 shadow-banking disclosure off your existing large-exposures data, noting that Article 433b(1)(f) institutions are expected to start from the 31 December 2027 reference date while other in-scope institutions should plan on the 31 December 2026 reference date, subject to the final adopted Commission text, and keep the EU SB1 timeline separate from the postponed C 37.00 reporting template. And when you write the legal basis into your disclosure control framework, cite 2024/3172 as amended, not the instruments it replaced, and track the ITS application date, the entry-into-force date and each reference date in separate fields once the Commission Implementing Regulation is published. The institutions that get this round wrong will mostly get it wrong on dates and on deleted templates, not on anything genuinely hard.

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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