Response to consultation on Guidelines on ESG scenario analysis
Question 14: Do you have any additional comments on the draft Guidelines on ESG Scenario Analysis?
If the final Guidelines are expected in Q4 2025 and the application deadline of January 2026 is not realistic, when could we expect certainty and clarity about the time of application? It is always key for banks to have sufficient certainty and time for planning. Having the final GL in Q4 2025 and an application date of 11th of January 2026 is not feasible.
The fact that EBA sees no impact for both draft GLs and the GLs on ESG risk given that there is no interaction between Omnibus and CRR/CRD is a cause for concern. In general we are of the opinion that there is an urgent need for a „CRR & CRD Omnibus“ as well because of course there are links. Let alone the calculation of the GAR and the impact on disclosure and reporting. (eg Implementing Regulation (EU) 2022/2453 refers directly to Delegated Regulation (EU) 2021/2178. If this Delegated Regulation will be amended substantially Implementing Regulation (EU) 2022/2453 has to be changed as well.)