Pillar 3 updates under CRR 3

In June 2026, the European Banking Authority (EBA) published the final draft Implementing Technical Standards (ITS) amending Commission Implementing Regulation (EU) 2024/3172 on Pillar 3 disclosures relating to environmental, social and governance (ESG) risks, equity exposures and aggregate exposure to shadow banking entities. These ITS complete the implementation of the new disclosure requirements introduced by the Capital Requirements Regulation 3 (CRR 3) and introduce a more proportionate and simplified approach to Pillar 3 disclosures.

Pillar 3 updates under CRR 3 (EN)

Watch video

Executive summary

The final ITS extend Pillar 3 ESG disclosure requirements to a broader range of institutions, including large listed and non-listed institutions, other listed institutions, large subsidiaries, small and non-complex institutions (SNCIs) and other non-listed institutions. At the same time, they introduce a proportionate approach based on institutions’ size and complexity, with different sets of templates depending on the type of institution.

Compared with the consultation draft, the final version introduces several important simplifications: they remove the disclosure templates for the Green Asset Ratio (GAR), the Banking Book Taxonomy Alignment Ratio (BTAR) and exposures to the top 20 carbon-intensive companies. In addition, SNCIs are no longer required to disclose qualitative information, and large subsidiaries are exempted from mandatory qualitative disclosures. The ITS are expected to apply from the reference date of 31 December 2026, except for SNCIs, for which the first reference date will be 31 December 2027.

Main content

The main changes to the disclosure framework are summarized below:

• Qualitative tables. The final ITS update the qualitative tables on environmental, social and governance risks, maintaining annual disclosure requirements for large institutions and other listed institutions. Large subsidiaries are not required to provide mandatory qualitative disclosures and may instead include a brief reference to the alignment of their strategy, governance and risk management with group-level disclosures. In addition, simplified ESG qualitative Table 1A applies to other non-listed institutions, but not to SNCIs, which will only be required to disclose quantitative information.
• Transition templates. Regarding transition risk, EU CRFR1 is updated to incorporate NACE Rev. 2.1, remove exposures to Paris-aligned benchmark exclusions and include a full breakdown of financed Scope 1, Scope 2 and Scope 3 emissions. Amendments are also introduced to EU CRFR1.1, as a simplified quantitative template for SNCIs and other non-listed institutions, as well as to EU CRFR3 and EU CRFR4, strengthening the disclosure requirements on the energy efficiency of real estate collateral, emission intensity, and sectoral alignment metrics.
• Physical risk and mitigating actions. For physical risk, EU CRFR2 replaces the regional NUTS 3 breakdown with a country-based geographical approach and replaces the acute/chronic risk split with four categories: temperature, wind, water and solid mass. The simplified version, EU CRFR2.1, will apply to other listed institutions and large subsidiaries. Template 10 is retained but revised to capture exposures that mitigate climate-related and environmental risks, regardless of whether they are aligned with the Taxonomy.
• Work approach. Implementing the new framework will require determining the category under which institutions fall in accordance with the proportionality approach defined by the EBA, identifying which templates apply in each case, and performing a gap analysis against the final requirements. Institutions will need to review data availability, update calculation methodologies, adapt internal instructions and disclosure templates, and conduct testing ahead of the first applicable reference date.

Access the technical note on Pillar 3 updates under CRR 3.