EBA peer review finds high compliance on Pillar 3 disclosures but calls for greater consistency

The European Banking Authority (EBA) has published a Discussion Paper addressing key performance indicators (KPIs) and other aspects of the Disclosures Delegated Act under Article 8 of the Taxonomy Regulation. The consultation is open until 12 August 2026.

The paper aims to gather public input on measures to simplify and enhance the usability of disclosures by credit institutions and investment firms. It is part of the EBA’s response to a targeted Call for Technical Advice from the European Commission received in March 2026, supporting the review of the Taxonomy Disclosures Delegated Act and broader sustainability disclosure efforts.

The Discussion Paper outlines preliminary proposals on:

• Simplifying KPIs related to fees, commissions, trading book, and off-balance sheet exposures for credit institutions;
• Simplifying the ‘other services’ KPI for investment firms;
• Aligning grandfathering provisions for financial instruments with the EU Green Bond Regulation;
• Clarifying group-level disclosures, including those by parent and other group entities;
• Addressing the treatment of operational expenditure KPI disclosed by non-financial undertakings in the calculation of financial KPIs.

The EBA coordinated with the European Insurance and Occupational Pensions Authority (EIOPA) and the European Securities and Markets Authority (ESMA) on cross-cutting issues. EIOPA’s consultation is available here, and ESMA’s consultation can be found here. The ESAs will submit their advice to the European Commission in October 2026.

Comments can be submitted via the EBA discussion page by clicking the “send your comments” button. The deadline is 12 August 2026. All contributions will be published unless requested otherwise. A virtual public hearing will be held on Thursday, 16 July, from 13:30 to 15:00 CEST. Registration is open until 13 July, 16:00 CEST.