DK position paper on the EBA consultation on Pillar 3 ESG disclosures

The German Banking Industry Committee has submitted a statement on the EBA consultation regarding Pillar 3 ESG risk disclosures. As part of the Omnibus Initiative, we advocate aligning disclosure requirements with the planned CSRD reliefs. We therefore welcome the EBA’s application of the proportionality principle and the reduction of requirements for SNCIs, but call for these reliefs to also be extended to other institutions such as listed institutions and large subsidiaries. Furthermore, we urge that ESG disclosure obligations should only apply once the ESG reporting requirements under the CRR have been fully implemented.