Introducing the Pulse on Impact, a new GRESB content series that spotlights how Asset Impact’s (a GRESB company) forward-looking climate data turns disclosure into decisions. Each episode, our experts and partners unpack new regulations, market shifts, and product updates to drive real-world decarbonization.

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From Scope to Templates: The 2025 EBA Pillar 3 Consultation

In this episode of Pulse on Impact, Alex Clark, Research Director at Asset Impact (a GRESB company), speaks with Dr. Inna Amesheva, Head of Regulatory Solutions at ESG Book about what’s new in the updated EBA Pillar 3 sustainability disclosures. They cover the expanded scope of institutions and proportionate timelines to 2029, the hazard-based physical-risk template with NUTS granularity, the temporary suspension of GAR/BTAR as templates align with the EU Taxonomy, and how PCAF-aligned proxies plus asset- and entity-level data can deliver more consistent, decision-useful reporting.

Download our updated EBA Pillar 3 Guide here.

Can’t listen? Read the full transcript below. Please note that edits have been made for readability.

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^{Alex: Welcome to Pulse on Impact, a GRESB series that spotlights how Asset Impact’s forward-looking climate data turns disclosure into decisions. Each episode, our experts and partners unpack new regulations, market shifts, and product updates to drive real-world decarbonization.}

^{I’m Alex Clark, Research Director at Asset Impact, a GRESB company. Today we’re talking about the revised European Banking Authority (EBA) Pillar 3 ESG disclosures. To help me, I’m joined by Dr. Inna Amesheva at ESG Book.}

^{Dr. Amesheva, very happy to have you on the podcast.}

^{Inna: Thanks for having me.}

^{Alex: The EBA Pillar 3 templates—of which there were 10 and now there may be fewer, at least temporarily—can be overwhelming, even for those familiar with the requirements. Let’s start with a high-level overview of what Pillar 3 is. Then, if you wouldn’t mind, give us a flavor of what’s expected to change, starting with the scope of institutions required to disclose.}

^{Inna: The EBA Pillar 3 framework is primarily a financial risk management and disclosure framework for banks—covering liquidity requirements, exposures, and disclosures—so regulators can address systemic risks. Alongside the financial templates, there’s a set of ESG-related templates. As you mentioned, there were originally 10 ESG templates, with a slightly shifted approach based on the latest consultation.}

^{Previously, Pillar 3 disclosures were limited to the largest, systemically important financial institutions. Now the scope expands to around 2,000 entities across the European banking system, including large non-listed institutions, small and non-complex institutions (both listed and non-listed), and the largest subsidiaries of banking groups. This is a substantial shift. Even smaller and less complex players must prepare sustainability reporting—albeit in a scaled and proportionate fashion. That brings us to data challenges. From your point of view, what are the biggest data challenges under the revised framework, and how can institutions start addressing them?}

^{Alex: Thanks, Inna, for the comprehensive overview. In our first edition of the Practical Guide earlier this year, we summarized the data challenges, and most of them remain. Institutions still need to comprehensively map sources of financed emissions today—and how these will evolve—and they remain on the hook for that in the revised disclosures.}

^{Difficulties include a lack of clarity and consistency in corporate disclosure documents, where differences in accounting standards and approaches are often implicit rather than explicit. You think you’re comparing apples to apples, but there’s no guarantee. There are gaps in scope coverage—most notably Scope 3—and gaps in company disclosures, especially for banks with exposures to companies that are not listed or don’t disclose in a way that matches the specific counterparty.}

^{In practice, the patchy data problem—coupled with Pillar 3’s stringent demands relative to other standards—means most banks will still use a combination of inconsistent reported data, sector averages, and proxies. That’s where Asset Impact comes in: we build a consistent, asset-based dataset designed to address completeness, consistency, and comparability issues. Even with the best will in the world—and with the joint benefits of our asset-based approach and ESG Book’s reported data and solutions—proxies will still be needed in some parts of the regulation. It’s helpful that the revised proposals give more clarity on proxies and estimates, aligning guidance with PCAF methodologies widely used for financed-emissions calculations.}

^{Inna: Exactly. The new templates provide much-needed clarity, and I echo the challenges you mentioned. Through our conversations with banks at ESG Book, we consistently see that banks need to combine multiple datasets for Pillar 3 reporting—there’s no one-stop solution, given the data’s complexity and the breadth of reporting. They often work with several providers to get the necessary information, which is challenging.}

^{A recurring gap is the lack of data for smaller portfolio holdings. On the real-estate side, when it comes to exposures—EPC labels or residential mortgages—these are areas of concern banks consistently cite. So it remains to be seen how this evolves.}

^{Alex: We’ve covered high-level challenges and data management issues. It would be useful to understand what has changed between the previous iteration earlier this year and the consultation draft issued in May. Could you walk us through the key updates to the disclosure templates—especially flashpoints like physical risk and the famous (or infamous) Green Asset Ratio?}

^{Inna: On physical risk, the revised templates propose a more granular, hazard-specific framework. Instead of a generic “acute vs. chronic” split, the new Template 5 breaks physical risk into four hazard types: temperature, wind, water, and solid mass. This lets banks pinpoint specific climate hazards. There’s also more regional granularity via NUTS regions—greater geolocation specificity to enhance spatial risk visibility. Finally, there’s more transparency on methodology. The implication is that banks will need geotagged data, hazard-specific risk mapping, and clear scoring frameworks.}

^{On the Green Asset Ratio (GAR) and the Banking Book Taxonomy Alignment Ratio (BTAR), the proposal aligns directly with the EU Taxonomy (following the latest Delegated Act), expanding scope to all six environmental objectives rather than just climate mitigation and adaptation. Reporting on GAR and BTAR has been suspended—voluntary for now—to align with Taxonomy timing. Sector reporting is updated to the latest NAICS classification. There are enhancements on real estate—clarity around methodology and EPC labels—and better guidance on proxies. And in Template 3 (climate alignment metrics), the emphasis shifts to GHG-intensity-based targets, mandating disclosure of baseline, 2030, and post-2030 emissions-intensity targets.}

^{Alex: Thank you for the overview. Turning to implications for banks—with timelines staggering out, in some cases to 2029—let’s break it down. The most broadly applicable requirements are robust climate-risk metrics. Concretely, that means focusing on exposures: understanding banking-book exposures to high-emission sectors and their geographic distribution to enable physical-risk analysis at the required granularity; separating emissions by scope—reporting total, Scope 1, Scope 2, and Scope 3 where possible; and using backups and proxies systematically to fill gaps.}

^{Forward-looking metrics are critical—baseline carbon-intensity year to 2030 targets and, where they exist, post-2030 targets at sector level. So there’s both a doubling-down on climate-risk information and an element of future-proofing: GAR definitions and what’s counted are more tightly linked to EU Taxonomy updates. We may see some inconsistency over the next 12–18 months, but the goal is smooth alignment. Why is this so important to European regulators, and how do you anticipate reporting practices changing? Is it worth making changes now—risking short-term misalignment—in pursuit of a greater good?}

^{Inna: EU-level regulations haven’t always been harmonized—think SFDR and the incoming CSRD. It’s important that financial-institution regulators and corporate-level regulators are interconnected. The Pillar 3 revision reflects that the EU Taxonomy is a living instrument. Changes within the Taxonomy should be automatically built into the EBA reporting framework to avoid repeated revisions.}

^{By embedding future-proofing—linking Pillar 3 disclosures automatically to the EU Taxonomy—the EBA enables continuous alignment with evolving sustainability standards, while improving operational efficiency, reducing manual compliance burden, and enhancing data integrity and auditability. With that in mind, where does Asset Impact’s work fit in supporting institutions to meet expanding requirements and ensure consistency across disclosures, Alex?}

^{Alex: Glad you asked. Asset Impact has been around for a few years. We began by building a database of physical assets tied to company ownership trees—so there’s no selection bias toward firms that disclose more. We start with the real-world footprint of physical activities and work backward, without discriminating across companies. The goal is to provide a separate data source that doesn’t rely purely on disclosures and is designed to provide near-complete coverage of physical activities and associated emissions. We started with sectors like power and oil & gas and have expanded to aluminum smelting, chemical production, and more.}

^{From a Pillar 3 perspective, underlying assets are geolocated, which makes our dataset a strong springboard for physical-risk analysis required by the templates. This is especially important for exposures to subsidiaries of listed companies with different owned assets than their parents; unlisted private companies not subject to the same disclosure rules; and other borrowers like state-owned enterprises and special-purpose vehicles not directly linked, in credit-risk terms, to parents or sponsors. The spatially explicit approach lets you see not just a single emissions datapoint, but where emissions come from, what’s produced where, in what quantities, and how exposed those locations are to physical risks—on top of transition risks—and how these interact, which is where Pillar 3 is heading.}

^{In our work with our team and partners like ESG Book, we’re expanding sector coverage and mapping our data efficiently to EU Taxonomy categories that underpin Pillar 3 and wider EU legislation—and to the physical locations where companies’ costs and revenues are most exposed. There’s no out-of-the-box, single-source solution for Pillar 3, and that’s unlikely to change because the requirements are so extensive. We’re not saying we provide the only source of truth on company emissions; rather, an independent view is highly complementary to company disclosures to understand what’s the same, what’s different, what’s omitted, and what differences in accounting approaches say about a company.}

^{Perhaps you can add to that, given ESG Book’s work here.}

^{Inna: The approaches are certainly complementary. Pillar 3 emphasizes transparency and stipulates a data hierarchy—especially relevant to BTAR in Template 9. First, banks should reach out to portfolio holdings to request information. If not available on a best-efforts basis, they can use third-party providers. Finally, proxies and estimations. ESG Book supports reported and estimated data on company emissions and EU Taxonomy exposures—and provides an engagement mechanism that enables banks to reach out efficiently through the ESG Book reporting platform. There’s a lot to consider in mixing and matching data approaches for Pillar 3.}

^{The consultation completed on 22 August. The EBA is considering responses and will issue the final regulatory technical standards sometime in Q4. I don’t have a specific timeline, so we’ll have to watch for the final version—there may be further changes.}

^{Alex: Agreed—watch this space. If there are further changes when the final standards are released, we’ll update our Practical Guide accordingly. In the meantime, if you’d like to learn more about the changes proposed in the May consultation drafts, the up-to-date Practical Guide is available for free download on both of our websites. Inna and I are happy to answer questions and explore how our organizations—separately or jointly—can help.}

^{Inna, thank you for joining me today. We hope you enjoyed listening, and please follow us for future episodes.}

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