The EACB welcomes EFRAG’s efforts to simplify the European Sustainability Reporting Standards (ESRS). However, the EACB considers that, despite notable progress, several provisions still pose challenges for preparers in the banking sector. In particular, while the reduction of data points and clarification of the double materiality assessment represent steps in the right direction, the practical implementation remains complex and resource-intensive. The EACB stresses the need for greater clarity in definitions, improved guidance to support consistent application, and transitional measures that ensure proportionality, especially for smaller and less complex institutions.
EACB also highlights the need for sectoral relevance across several ESRS provisions. Banks should not be obliged to disclose absolute greenhouse gas (GHG) emission reduction targets when they have only set intensity-based targets, as such calculations would be unreliable and misaligned with the sector’s role in financing the transition. Furthermore, EACB stresses that relief measures must not compromise data quality or comparability and that clarity is needed on the treatment of consolidation perimeters and transitional provisions. While acknowledging improvements in readability and structure, EACB urges EFRAG to provide practical tools, such as cross-reference tables, to facilitate the transition from previous standards and maintain the alignment of sustainability reporting with the realities of financial sector operations. Overall, the EACB advocates for simplification, proportionality and legal clarity as key principles to ensure that the ESRS framework remains workable and effective for the banking sector.