Disclosing Less: How the EBA Scales Back ESG Reporting Under CRR3

On 22 June 2026 the European Banking Authority (EBA) submitted final draft implementing technical standards (ITS) on Pillar 3 disclosure, filed as EBA/ITS/2026/02. The most conspicuous change: the templates for the Green Asset Ratio (GAR) and the Banking Book Taxonomy Alignment Ratio (BTAR) drop out of banks' disclosure obligations altogether.

The accompanying relief figures have circulated since publication: 37 per cent fewer data points for large institutions, 84 per cent fewer for small ones. Both are correct, and they measure against entirely different starting points. For capacity planning in a reporting function, that difference decides everything.

Three classes, three baselines

The EBA grades disclosure by size and complexity, calling the model a “core plus supplement approach”. Four values from the report's data point table need setting side by side.

Large listed institutions disclose 2,614 data points today. Under the new standard the figure is 1,648, which the report puts at a reduction of “approximately 37%”. Other listed institutions and large subsidiaries arrive at 1,368 data points, and small and non-complex institutions (SNCIs) at 269.

Those last two figures measure against large institutions under the new standard, and not against today's position. The EBA's press release is precise about it: large institutions disclose 37 per cent fewer data points than now, medium ones 17 per cent fewer, and SNCIs 84 per cent fewer “than large institutions”. Read the 84 per cent as relief against the status quo and you overstate it considerably. Small institutions carried little in the way of their own ESG disclosure obligations to begin with.

The third figure, 17 per cent for the middle class, is missing from most retellings. It is what makes the grading visible. In passing: “medium institutions” is EBA press language rather than a category of the capital requirements regulation; the final report calls them “Other listed institutions and large subsidiaries”.

What exactly disappears

Templates 6 to 9 leave the Pillar 3 standard: the GAR summary, the templates on GAR assets and the GAR KPI flow from Annex VI of Delegated Regulation (EU) 2021/2178, and BTAR templates 9.1 to 9.3. The report is unambiguous, stating that the amending standards “are dropping the Green Asset Ratio (GAR)-related disclosures and any disclosures related to the alignment of institutions financial exposures with the EU Taxonomy Regulation.”

A fourth template goes as well and is rarely mentioned: template 4 on exposures to the twenty most carbon-intensive firms. The EBA cites limited usefulness and methodological problems; concentration risk moves into supervisory reporting instead.

Template 10 on mitigating actions survives and is widened in substance. Institutions will have to disclose all climate-risk-mitigating exposures, whether or not they align with the EU taxonomy. Until now only taxonomy-aligned positions and a few edge cases qualified. Part of the climate data therefore migrates into a broader template that is no longer tied to the taxonomy.

What the GAR removal does not mean

Two boundaries belong with this. First, the removal touches only banks' Pillar 3 obligation. The GAR reporting duty for non-financial corporates under the EU Taxonomy Regulation remains, though narrowed in scope: after the omnibus package only firms with turnover above €450m that also fall under the Corporate Sustainability Reporting Directive (CSRD) must report. A separate one-month consultation on amendments to that delegated act runs in parallel.

Second, the news is less dramatic for market practice than it sounds. In August 2025 the EBA had already issued a no-action letter that effectively suspended templates 6 to 10. The removal formalises a position that has been lived with for roughly a year.

Why the timetable is not yet a timetable

Here lies the practically most important caveat. The EBA gives 31 December 2026 as the expected reference date for large and medium institutions and 31 December 2027 for SNCIs. It qualifies that itself: the standards “are expected to apply with a reference date of 31 December 2026, and 31 December 2027 for SNCIs – this notwithstanding any further adjustment needed as a result of the finalisation of Commission's work.”

The reason is procedural. On 22 June the EBA merely submitted the draft to the European Commission for adoption. The Commission has to adopt it by implementing regulation, after which come the non-objection period for Parliament and Council and publication in the Official Journal. No adoption by the Commission has been evidenced. Treat the standard as settled in project planning and you are planning against a draft.

The real relief for small institutions

For SNCIs the easing sits less in the number of data points than in the process. The EBA will centrally pre-populate ESG information for these institutions and publish it on their behalf in the Pillar 3 data hub, drawing on supervisory reporting already submitted. In its words: “the EBA will centrally pre-fill and disclose ESG information in the Pillar 3 Data Hub on behalf of SNCIs based on supervisory reporting.”

The data hub itself is a separate and larger undertaking under Articles 434 and 434a of the capital requirements regulation as amended by CRR3. It brings all Pillar 3 disclosures together at a single electronic access point on the EBA website, and its own final draft standards appeared back in February 2025. Implementation still requires a data point model and an XBRL taxonomy, along with an updated mapping tool between disclosure and supervisory reporting, announced for 2026 without a firm date.

What this means in practice

Four starting points for reporting, compliance and internal audit.