European Banking Authority Publishes Survey on Banks' Environmental, Social and Governance Risk Disclosure Frameworks

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Shearman & Sterling LLPThe European Banking Authority has published a survey designed to collect information on large banks' disclosure practices on environmental, social and governance risks. The EU Capital Requirements Regulation implements the Basel Committee on Banking Supervision's Pillar 3 disclosure requirements, which require banks to disclose information about their risks and risk management procedures and policies. In 2018, the Basel Committee published updated Pillar 3 requirements. The revised CRR, published in June 2019, incorporates the revised Basel Committee disclosure standards and mandates the EBA to produce draft Implementing Technical Standards to ensure comparability of the disclosures made with international non-EU active banks.
 
Among the EBA's mandated ITS are standards specifying uniform disclosure formats, and associated instructions for the disclosure by institutions of prudential information on ESG risks. The survey is intended to assist the EBA in developing these ITS and to inform the short-term expectations specified in the EBA's Action Plan on Sustainable Finance. It is aimed at large banks that will be subject to the ESG risk disclosure requirements. The survey will be open until October 16, 2020, and participation is voluntary.
 
There are three main parts to the survey: 

  1. General questions on the current status of banks' ESG disclosures. 
  2. Questions on the interaction between banks' Pillar 3 disclosures and other policy initiatives, such as the non-financial reporting directive. 
  3. Forward-looking questions on the implementation of upcoming disclosure requirements under CRR.

The ITS will ultimately form part of the EBA's comprehensive ITS on banks' public disclosures under CRR, which reflect Pillar 3 disclosure requirements. The EBA published its final report on other aspects of the comprehensive ITS in June 2020 but noted that the ESG disclosure provisions, among others, would be consulted on and added to the comprehensive disclosure ITS at a later stage. In its Action Plan on Sustainable Finance, the EBA explained that the ESG-related disclosure requirements under CRR will be applicable from June 2022.
 
View the EBA's survey.
 
View details of the EBA's Action Plan on Sustainable Finance.
 
View details of the EBA's final report on the comprehensive ITS on banks' public disclosures under CRR.

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