The role of banks in the sustainability transition and resilience building
The banking sector remains firmly committed to sustainable development, nature protection, and the responsible use of resources, in line with the EU's environmental and resilience objectives. The shift towards green energy and a circular and resilient economy is central to strengthening EU competitiveness, resilience, and strategic autonomy. This commitment remains strong as we navigate a complex and evolving landscape.
Banks cannot mandate the transition on their clients, as sustainability investments must be economically viable and beneficial from the client's perspective. However, banks play a crucial enabling role by supporting clients through early engagement, advisory services, and financing. They raise awareness of ESG risks, integrate long-term considerations into decision-making and pricing, and promote business transformation while safeguarding financial stability, collaborating with key stakeholders to drive the transition.
Our objectives
Our goal is to ensure that banks can support the green transition through coherent, stable and effective and enabling policies, tools and scalable financing mechanism. To achieve this, we advocate for:
- Simple, coherent and practical regulatory and non-regulatory framework that fosters the banking sector's ability to support the transition of their clients;
- Availability of effective tools, de-risking mechanism and scalable public-private financing;
- The financial sector's resilience to ESG risk.
EBF’s contribution to the dialogue on sustainable finance
We work with expert from the banking sector under strategic coordination of senior representatives from the national banking associations. We are focusing on the key aspects of the Sustainable Finance regulation, ESG risk management and supervision but also industry regulation and initiatives beyond regulation increasing economic viability of the transition which is essential for its financing. We are also participating in several cross-sectoral and standard setting initiatives and industry groups at EU and international level and partnering with relevant stakeholders on various initiatives to advance our objectives.
Key EBF positions
Sustainability-related financial risk will become integral part of risk management framework and risk management practices. EBF is taking active part in the development of new methodologies and collection of experience necessary for proper integration of climate related dimension into the risk management.
EBF Resources to support ESG Risk Management Documents:
EBF Response to the consultation paper on Joint ESAs Guidelines on ESG Stress Testing - 16 September 2025
EBF Proposal for a Phased-in Implementation of the EBA ESG Risk Management Guidelines - 11 June 2025
EBF Response to the EBA consultation paper on Climate Scenario Analysis - 15 April 2025
EBF Response to the EBA Consultative Document Guidelines on ESG risks management - 22 April 2024
One-off Fit-for-55 climate risk scenario analysis EBF response to the EBA consultation - 16 October 2023
EBF response to the EBA Discussion Paper on the role of environmental risks in the prudential framework - 01 August 2022
EBF response to BCBS Consultation ‘Principles for the effective management and supervision of climate-related financial risks’ - 01 August 2022
Pillar 1 capital charge for climate risk: Wrong tool for the right purpose - 09 May 2022
Management and supervision of ESG risks for credit institutions and investment firms: EBF response to EBA consultation - 04 February 2021
EBF welcomes the Omnibus simplification initiative, which will significantly reduce the reporting obligations of EU companies. However, for the simplification to be effective, it must be fully reflected in both the regulatory requirements to banks and supervisory expectations.
Simplification documents:
EBF submits recommendations to further streamline sustainability reporting in the EU - 29 September 2025
Joint Associations Statement Taxonomy Delegated Act - 2 October 2025
Revised EBF positioning on data and transition plans aspects of the Omnibus proposal - 22 September 2025
Simplification of the EU Sustainable Finance Framework Omnibus Legislative Proposal - February 2025
EBF response to European Commission consultation on Taxonomy Disclosures Delegated Act - 28 March 2025
EBF Submits Letter to EU Institutions on ESG Regulatory Simplification - 1 April 2025
ESRS Set 1 revision: Questionnaire for public feedback – EBF RESPONSE - 6 May 2025
Relevant, reliable and comparable data are necessary not only to comply with the envisaged EU regulations (taxonomy, disclosures) and for proper and efficient risk management, but also for further development and scaling up of sustainable finance.
EBF Data, Disclosures & Reporting documets:
EBF Response to EBA consultation Article 8 DDA - 31 July 2026
EBF Responds to the Commission’s Consultation on Revised Sustainability Reporting Standards - 4 June 2026
EBF Strongly Supports the Efforts to Reduce the Complexity and Increase the Usability of Sustainability-Related Disclosures for Capital Markets - 27 February 2026
EBF submits recommendations to further streamline sustainability reporting in the EU - 29 September 2025
EBF Calls for Pragmatic Simplification of Sustainable Finance Disclosure Regulation - 5 June 2025
EBF Calls for Pragmatic Simplification of European Sustainability Reporting Standards - 6 May 2025
EBF Response to the consultation – Taxonomy Disclosures Delegated Act - 26 March 2025
EBF Response to the Basel Committee’s consultation on a Pillar 3 disclosure framework for climate-related financial risk - 18 March 2024
EBF response to the EFRAG ESRS Implementation Guidance consultation - 13 February 2024
EBF response to the SFDR consultation - 14 December 2023
EFRAG should reprioritise its activities towards SMEs: joint letter from SMEunited and EBF - 4 May 2023
Letter to the EC on the EFRAG funding for the development of credible and successful ESRS - 26 April 2023
EBF consultation response on the International Sustainability Standards Board (ISSB) Exposure Drafts - 1st August 2022
The European Banking Federation on the latest developments in the legislative process of the proposal for a corporate sustainability reporting directive - 25 February 2022
Proposal for the Corporate Sustainability Reporting Directive: EBF position - 14 September 2021
EBA consultation on draft technical standards on Pillar 3 disclosures of ESG risks: EBF response - 2 June 2021
EBF response to the IFRS Foundation consultation on the global approach to sustainability reporting and on possible Foundation role - 7 January 2021
EBF Response to ESMA’s consultation on Article 8 - 1 December 2020
Non-Financial reporting standard setting. EBF views and input to the personal mandate of EFRAG’s President - 30 October 2020
Pillar III ESG disclosures and Article 8 of the Taxonomy Regulation - 16 October 2020
EC’s Inception Impact Assessment on art. 8: EBF feedback | EBF European Banking Federation - 8 September 2020
Joint ESA consultation on Sustainable Finance disclosures – EBF response - 15 July 2020
A centralized register for ESG data in EU: EACB, EBF, EFAMA, ESBG, IE, PE Joint Letter - 10 June 2020
Non-Financial Reporting Directive Review: EBF response - 9 June 2020
Inception Impact Assessment on the Non-Financial Reporting Directive: EBF response - 2 March 2020
IIF & EBF: Global industry survey finds firms seek alignment on climate risk analysis, measurement, and disclosure approaches | EBF European Banking Federation - 28 January 2020
Report on climate-related disclosures: EBF response - 31 January 2019
EP draft report on disclosures on sustainable Investments: EBF proposal for amendments - 12 September 2018
Green Bonds and Green Covered Bonds may prove instrumental in mobilising the bond market for climate change solutions. The Green Bond market has considerably raised volumes of issuances in the last years and is expected to be further fostered by the EU Green Bond Label, following the proposal for an EU Green Bond Standard.
EBF Green bonds documents:
Proposal for a regulation on European Green Bonds: EBF position - 10 December 2021
Targeted consultation on the establishment of an EU Green Bond Standard: EBF response - 02 October 2020
EU Green Bond Standard: EBF response - 08 April 2019
A harmonised taxonomy is important to remove uncertainty, ensure comparability and allow competitive solutions. The success of the taxonomy will depend on the usability and on the way the taxonomy will be implemented. Automatisation of the processes and integration into the IT systems has a great potential for acceptance, successful adoption and implementation of the taxonomy.
EBF Taxonomy documents:
EBF Calls for More Ambitious and Structural Simplification of Taxonomy Alignment Assessment – EBF - 15 April 2026
Call for Evidence on EC guidance on DNSH Application Under 2028-2034 MF - 1 April 2026
Call for Evidence: Review of the EU Taxonomy Environmental and Climate Delegate Acts - 05 December 2025
EBF on the EU Platform’s Preliminary Recommendations for Technical Screening Criteria for the EU Taxonomy - 24 September 2021
Draft Report of the Platform on Sustainable Finance on a Social Taxonomy: EBF response - 14 September 2021
Draft Report on Taxonomy Extension Options linked to Environmental Objectives: EBF response - 14 September 2021
European Commission Taxonomy Article 8 Delegated Act: EBF response - 01 June 2021
Proposals for recognition of transition finance in the EU legislation: EBF response - 11 March 2021
EBF-UNEP FI report outlines path for application of EU Taxonomy to core banking services - 26 January 2021
EBF feedback on the draft Taxonomy Delegated Act - 17 December 2020
Testing the application of the EU Taxonomy to core banking products: High level recommendations - 10 December 2019
TEG report on Taxonomy: EBF comments | EBF European Banking Federation - 17 September 2019
European banks support EU priorities in Sustainable Finance - 20 Mar 2019
Climate change mitigation activities: EBF responds to the TEG Taxonomy consulation - 27 February 2019
Usability of the taxonomy: EBF responds to European Commission’s Technical Expert Group consultation - 27 February 2019
Taxonomy: EBF responds to the EP draft report - 14 December 2018
EBF supports Commission framework to facilitate sustainable investment - 06 September 2018
Sustainable Finance: Banks urge clarity in EU Action Plan - 31 January 2018
The objective of the EU ecolabel is to increase the trust of retail investors in investing in financial products pursuing sustainability objectives.
EBF Ecolabel documents:
EBF views on the Ecolabel Report - 15 April 2020
EU Ecolabel for Financial Products Questionnaire: EBF response - 15 February 2019
Sustainability ratings and research has a potential to play an important role in allocation of capital to sustainable activities.
EBF Sustainability, research and rating documents:
EBF final response - ESG Ratings 2022 - 27 June 2022
EBF Response: ESMA Call for Evidence on Market Characteristics for ESG Rating Providers in the EU | EBF European Banking Federation - 14 March 2022
EBF input to the Commission’s discussion paper for the workshop on sustainability research and ratings - 08 May 2019
Proposed EU measures on Climate Transition and Paris-aligned benchmarks to address the risk of greenwashing and improve transparency and comparability of information.
EBF Benchmarks documents:
EBF Letter to EP on carbon benchmarks - 30 November 2018
EBF Corporate Governance & Due Diligence documents
EBF response: Corporate Sustainability Due Diligence Directive (CSDD) - 26 June 2022
Consultation Document Proposal for an Initiative on Sustainable Corporate Governance: EBF response - 08 February 2021
EBF Renewed sustainable finance strategy documents
- Renewed Sustainable Finance Strategy: EBF response
- Renewed Sustainable Finance Strategy: Important considerations from the banking sector (PDF)
Joint letter calling for safeguarding the proper functioning of the EU ETS - 21 September 2022
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