NFU Consultation Reply to EBA on ESG Related Risk Disclosures

Summary

Background
On 22 May 2025, the European Banking Authority (EBA) launched a public consultation proposing amendments to Pillar 3 disclosures under the CRR3 framework. The aim is to enhance ESG-risk, equity exposure, and shadow-banking disclosures with greater transparency and consistency—especially by simplifying requirements for small and medium-sized banks, offering clarity for large ones, and building in transitional flexibility.

NFU’s Response
The Nordic Financial Unions (NFU) acknowledge the legal uncertainty surrounding the transitional application of ESG disclosure requirements pending the adoption of the Sustainability Omnibus Directive but see substantial risks against relying on informal “no-action letters” during the transition period, arguing that such letters can introduce confusion and unequal treatment across institutions. Instead, NFU urges the use of legally binding transition periods and insists that ESG disclosure frameworks must explicitly include social dimensions—such as workers’ rights, diversity, and upskilling—to ensure a fairer, more resilient, and future-ready financial sector.