Response to consultation on Implementing Technical Standards on amended disclosure requirements for ESG risks, equity exposures and aggregate exposure to shadow banking entities

1. Do you have any comments on the proposed set of information for Large institutions?

WWF notes the EBA objective to simplify Pillar 3 ESG disclosures. For WWF it is positive to improve consistency, avoid duplications within the prudential rules and with other EU legislation, and ensure that ESG disclosures are material nor useful from a prudential perspective. 

However, this should not compromise transparency, and risks of incomplete or misleading information must be avoided. Indeed, prudential rules are a critical part of the EU banking regulatory framework and adequate transparency is critical to mitigate risks, including ESG-related financial risks, and ensure sound financial decision making.

WWF generally supports the changes from EBA to the templates, but has recommendations on several points:

• Template 1: It is focused on financed emissions exclusively. This is problematic as very significant capital market activities from large institutions have emissions which are not falling under this category, hence are not reported nor taken into consideration to assess related risks. For instance, 61% of the financial support from the 6 largest US banks to fossil fuel companies in the period 2016-2022 was provided through capital market activities (source: Banktrack, “New report: US banks’ role in capital markets reveals a hidden pipeline for fossil fuel financing”, July 2023): this would not be accounted at all under the reporting of financed emissions. This leads to largely inaccurate emissions disclosures and assessments of climate-related financial risks for large institutions. But there are precedents: several banks like HSBC or Barclays are now reporting on it (Source: Reclaim Finance, Bank transition plans: a roadmap to nowhere, April 2025). To fix this significant loophole, EBA should require reporting on financed emissions AND facilitated emissions.
• Template 3: There is nothing specific on non-GHG emission metrics used by banks. This is inconsistent with the recent EBA Guidelines on ESG risks (EBA, Final Guidelines on the management of ESG risks, January 2025) which identifies such metrics as relevant. In particular, WWF strongly recommends using the metric of clean to fossil fuel ratio recommended in the EBA Guidelines (“sustainable power supply to fossil fuel financing ratio”), and which provides the balance of banks’ support for clear renewable energy versus fossil fuels, a very important indication of banks’ energy transition state of play and related financial risks. The French Institut Louis Bachelier developed a methodology for this metric (source: Stéphane Voisin and al, Green/Brown ratio: a zoom on the Energy Supply Ratio (ESR), April 2025). WWF therefore recommends EBA to add at least the the “clean to fossil fuel” metric.
• Other recommendations for improvements: see further questions below.

2. Do you have any comments on the simplified set of information for Other listed institutions and Large subsidiaries?

WWF is partly concerned with the EBA choice to radically simplify the disclosure requirements for other listed institutions and large subsidiaries by exempting them from disclosing on half of the templates (6 templates against 13 for large institutions). 

While we appreciate that this approach may be proportionate and relevant for some templates, it exempts significant institutions from providing important ESR risk management information, in particular information in templates 3 and 4. Indeed, exempting other listed institutions and large subsidiaries from reporting under these two templates means that they will disclose very limited information on their exposure to transition-related risks. This is particularly problematic for high-carbon sectors, in particular fossil fuels, in which asset stranding is already happening (for coal plants in the EU typically) and will increase.

We therefore strongly recommend EBA to require that other listed institutions and large subsidiaries report on templates 3 and 4.

Finally, no disclosure related to GAR or BTAR would be required to other listed institutions and large subsidiaries, which is problematic as the EU Taxonomy, to have impact, was conceived to be a building block in the EU sustainable finance framework and too limited disclosure would render this approach ineffective. However, WWF appreciates that the GAR and BTAR currently suffer various methodological issues, so until they are fixed by the Commission building on Platform’s technical recommendations, encouraging voluntary disclosures would be a pragmatic way forward.

3. Do you have any comments on the simplified set of information proposed for SNCI and other non-listed institutions?

WWF acknowledges the demand from SNCIs for simplified standards regarding ESG risk disclosures, but it should not come at the cost of transparency nor weakens the meaningfulness and comparability of disclosures.

More specifically:

• Template 2 on real estate loans by energy performance: this information is already collected by SNCIs to assess collateral value, hence it should be easy for them to disclose it in Template 2.
• Template 3: It is necessary to include SNCIs in the transition targets and progress reporting: it is critical information on institutions’ risk management and their contribution to mitigating systemic climate risk
• Template 4: The effort required for its disclosure would be minimal (see Q22) and thus it should remain a part of the SNCIs’ ESG disclosure requirement.

As a result, WWFs recommends EBA to at least include the following specific elements in its simplified template:

• GHG targets
• Underlying GHG emissions
• Exposure to high carbon sectors and companies, in particular the fossil fuel sector. 

8. Do you have any comments on the proposed additions and deletions to the sector breakdown?

WWF strongly supports the proposed sector breakdowns which are more granular. In addition, we recommend that the fossil fuel industry is also treated in a separate way distinct from other sectoral classifications, given its highest climate-related financial risks.

Building on the elements of the EBA consultation document p45, it should be noted that:

• Disclosure on financial services to fossil fuel companies is already common practice and banks already provide data in aggregate terms;
• The CSRD/ESRS requires large companies to disclosure their own exposure to coal, oil, gas;
• Several resources including free-to-use databases are available to banks to identify fossil fuel companies in a more granular way than NACE codes. This notably includes the Global Coal Exit List (GCEL: https://www.coalexit.org/) and Global Oil and Gas Exit List (GOGEL: https://gogel.org/).
• Fossil fuel disclosure is complementary to a disclosure based on sectoral codes. Relying solely on NACE codes would not be consistent with CRR3 which requires fossil fuel disclosures.

10. Do you have any views with regards to NACE code K – Telecommunication, computer programming, consulting, computing infrastructure and other information service activities, and in particular K 63 - Computing infrastructure, data processing, hosting and other information service activities, whether these sectors should be rather allocated in the template under section Exposures towards sectors that highly contribute to climate change?

WWF supports the inclusion of the sector related to the NACE code K, particularly sector K 63. Recent data suggest that emissions from this sector are skyrocketing and will keep growing fast in the near future at least – notably given the developments of data centers and Artificial Intelligence – and WWF is also concerned about the related water consumption.

It is therefore necessary to incorporate it into in Template 1 and Template 1A.

12. Do you have any further comments on Template 1?

As raised in Q1, Template 1 is focused on financed emissions exclusively. This is quite problematic as very significant capital market activities from large institutions have emissions which are not falling under this category, hence are not reported nor taken into consideration to assess related risks. For instance, 61% of the financial support from the 6 largest US banks to fossil fuel companies in the period 2016-2022 was provided through capital market activities (source: Banktrack, “New report: US banks’ role in capital markets reveals a hidden pipeline for fossil fuel financing”, July 2023): this would not be accounted at all under the reporting of financed emissions. This leads to largely inaccurate emissions disclosures and assessments of climate-related financial risks for large institutions. But there are precedents: several banks like HSBC or Barclays are now reporting on it (Source: Reclaim Finance, Bank transition plans: a roadmap to nowhere, April 2025).

To fix this significant loophole, EBA should require reporting on financed emissions AND facilitated emissions.

In addition, it is also beneficial to have access to information about sustainable investments, as they contribute to the overall ESG risk assessment of the bank by market stakeholders. This is why the Column C ("Of which environmentally sustainable") disclosures are important as well, as they provide this information. Banks will still be able to rely on a clear definition to label their exposure. Following this idea, we find it useful to also include exposures which are aligned with the five other EU Taxonomy objectives: climate adaptation, water and marine resources, circular economy, pollution prevention and control, biodiversity), which will lead to a better understanding of environmental and climate risks.

15. Do you have any further comments on Template 1A?

Consistently with our response to Q9, we recommend EBA to require reporting on financed emissions AND facilitated emissions, as the latter could account for a huge part of their ESG risks. Like other financial institutions, SNCIs will have to assess climate risks from facilitated activities through the Climate Resilience Analysis exercise, hence making the disclosure of these exposures both relevant and feasible.

We also recommend EBA to include a column “Of which environmentally sustainable”, at a voluntary basis at least, in Template 1A. This would enable SNCIs to highlight the share of their exposure that aligns with EU Taxonomy objectives and provide valuable insights into their transition planning and financing strategies.

20. Do you have any further comments on Template 2?

Given that SNCIs already collect data on the energy performance of real estate loans collateral for valuation purposes, reporting this information in Template 2 would not be burdensome. Doing so would then offer valuable information to market participants into their real estate portfolios and the transition risks they may face.

21. Do you have any comments on Template 3?

As we put in Q1: in Template 3, there is nothing specific on non-GHG emission metrics used by banks. This is inconsistent with the recent EBA Guidelines on ESG risks (EBA, Final Guidelines on the management of ESG risks, January 2025) which identifies such metrics as relevant. In particular, WWF strongly recommends using the metric of clean to fossil fuel ratio recommended in the EBA Guidelines (“sustainable power supply to fossil fuel financing ratio”), and which provides the balance of banks’ support for clear renewable energy versus fossil fuels, a very important indication of banks’ energy transition state of play and related financial risks. The French Institut Louis Bachelier developed a methodology for this metric (source: Stéphane Voisin and al, Green/Brown ratio: a zoom on the Energy Supply Ratio (ESR), April 2025). WWF therefore recommends EBA to add at least the “clean to fossil fuel” metric.

For Other listed institutions and large subsidiaries, template 3 could be turned into a simplified template 3A (limited to points a to i). GHG intensity disclosure could also be limited to high-emitting sectors.

22. Do you have any comments with the proposals on Template 4 and the instructions?

WWF recommends EBA to clarify which exposure should be disclosed in the Template 4: the top 20 most carbon-intensive firms in the world OR the top 20 most carbon-intensive firms in the bank's balance sheet. In both cases, facilitated emissions should also be included in this template (se our response to Q12). Otherwise it is confusing:

• If it is about the Top 20 worldwide, EBA should ensure that the list of the top 20 carbon-intensive firms remains consistent across all banks;
• If it is about the Top 20 polluting firm in the bank portfolio, EBA should require banks to include GHG intensity metrics corresponding to the exposure, in order to ensure comparability across banks.

For Other listed institutions and large subsidiaries, we recommend that Template 4 is turned into a simplified template 4A (limited to the three points a, d, e). Such a template 4A could also be transformed to focus on fossil fuel companies, providing the fact they have been clearly identified as a source of ESG risk and concentrating climate related risk (WWF notes that EIOPA acknowledged that fossil fuel assets are higher risk than average). This fossil fuel focus would be facilitated by the availability of the Global Coal Exit List (GCEL) and Global Oil and Gas Exit List (GOGEL). 

23. Do you have any views on whether this template could be improved with some more granular information in the rows, by requesting e.g. split by sector of counterparty or other?

Consistently with our response to Q8, WWF recommends that the fossil fuel industry is also treated in a separate way distinct from other sectoral classifications, given its highest climate-related financial risks.

Building on the elements of the EBA consultation document p45, it should be noted that:

• Disclosure on financial services to fossil fuel companies is already common practice and banks already provide data in aggregate terms;
• The CSRD/ESRS requires large companies to disclosure their own exposure to coal, oil, gas;
• Several resources including free-to-use databases are available to banks to identify fossil fuel companies in a more granular way than NACE codes. This notably includes the Global Coal Exit List (GCEL: https://www.coalexit.org/) and Global Oil and Gas Exit List (GOGEL: https://gogel.org/).
• Fossil fuel disclosure is complementary to a disclosure based on sectoral codes. Relying solely on NACE codes would not be consistent with CRR3 which requires fossil fuel disclosures.

29. Do you have any comments on the proposal related the BTAR and to keep it voluntary?

In principle WWF welcomes the use of the BTAR, which should offer a broader view of the EU Taxonomy eligibility and alignment of banks. However, there are currently various methodological issues on GAR disclosures (see e.g. AMF, Study on the taxonomy reporting of financial institutions, December 2024). This lack of integrity is likely to be reproduced for BTAR disclosures. 

We therefore recommend EBA to work, together with the European Commission and the EU Platform on Sustainable Finance, in order to clarify the GAR methodology. Once this work is completed, mandatory disclosures of BTAR should become a very relevant addition to GAR disclosures.

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