+Guidelines on the management of ESG risks (EBA/GL/2025/01)
---+1. Compliance and reporting obligations
------+Status of these guidelines
---------+1. This document contains guidelines issued pursuant to Article 16 of Regulation (EU) No 1093/2010 …
---------+2. Guidelines set the EBA view of appropriate supervisory practices within the European System of …
------+Reporting requirements
---------+3. According to Article 16(3) of Regulation (EU) No 1093/2010, competent authorities must notify …
---------+4. Notifications will be published on the EBA website, in line with Article 16(3). 1 Regulation …
---+2. Subject matter, scope and definitions
------+Subject matter and scope of application
---------+5. These guidelines specify robust governance arrangements institutions need to have in place in …
---------+6. These guidelines address the ESG risk management processes of institutions as part of their …
---------+7. Competent authorities and institutions should apply these guidelines in accordance with the …
------+Addressees
---------+8. These guidelines are addressed to competent authorities as defined in Article 4(2) point (i) of …
------+Definitions
---------+9. Unless otherwise specified, terms used and defined in Directive 2013/36/EU and Regulation (EU) …
---+3. Implementation
------+Date of application
---------+10. These guidelines apply to institutions other than small and non-complex institutions from 11 …
---+4. Reference methodology for the identification and measurement of ESG risks
------+4.1 Materiality assessment
---------+11. As part of the reference methodology for institutions’ identification and measurement of ESG …
---------+12. The materiality assessment of ESG risks should be performed as an institution-specific …
---------+13. The materiality assessment of ESG risks should use a risk-based approach that takes into …
---------+14. With a view to comprehensively assessing the materiality of ESG risks, institutions should …
---------+15. With regard to the materiality assessment of environmental risks, institutions should use both …
---------+16. Institutions should substantiate and document as part of their ICAAP their materiality …
---------+17. Institutions should develop and implement measurement methods, risk management arrangements and …
------+4.2 Identification and measurement of ESG risks
---------+18. As part of the minimum standards to identify and measure ESG risks, i nstitutions’ internal …
---------+19. To ensure a proper identification and management of ESG risks, institutions should consider the …
---------+20. With regard to environmental risks, internal procedures and methodologies should allow …
---------+21. With regard to social and governance risks, where quantitative information is initially …
---------+22. With regard to the interactions between the different categories of, respectively …
---------+23. Institutions ’ internal procedures should provide for the implementation of sound information …
---------+24. Institutions ’ internal procedures should ensure that institutions gather and use the …
---------+25. Institutions ’ internal procedures should build on both internally and externally available ESG …
---------+26. Institutions should assess which other sources of data would effectively support the …
---------+27. Where the quality or availability of data is initially not sufficient to meet risk management …
---------+28. For large corporate counterparties as defined by Article 3(4) of Directive 2013/34/EU …
---------+29. For exposures towards other types of counterparties than large corporates, institutions should …
---------+30. Institutions’ internal procedures should provide for a combination of risk assessment …
---------+31. At an exposure-based level, in line with the provisions in paragraphs 126 and 146 of the EBA …
---------+32. With regard to the assessment of environmental risks at exposure level, institutions ’ internal …
---------+33. Where data needed to assess certain criteria is not yet available, such as for smaller …
---------+34. With regard to the assessment of social and governance risks at exposure level, institutions …
---------+35. Institutions ’ internal procedures should provide for sector-based and portfolio-based …
---------+36. With regard to non-climate related ESG factors, large institutions should develop: a) methods …
---------+37. With regard to climate- related risks, institutions’ internal procedures should provide for the …
---------+38. For the purposes of paragraph 37, institutions should use scenarios that are science-based …
---------+39. For the purposes of paragraph 37, institutions should determine the appropriate scope of the …
---------+40. Institutions should justify and document their methodological choices including the choice of …
---------+41. Institutions should consider insights gained from climate portfolio alignment methodologies to …
---------+42. In addition to exposure-based, sector-based, portfolio-based and portfolio alignment methods, i …
---+5. Minimum standards and reference methodology for the management and monitoring of ESG risks
------+5.1 ESG risk management principles
---------+43. For the purposes of integrating ESG risks into the institution-wide risk management frame-work …
---------+44. Institutions should embed ESG risks within their regular risk management systems and pro-cesses …
---------+45. Institutions should develop a robust and sound approach to managing and mitigating ESG risks …
---------+46. Institutions should determine which combination of risk management and mitigation tools would …
------+5.2 Strategies and business models
---------+47. Institutions should account for ESG risks when developing and implementing their overall …
---------+48. For the purposes of paragraph 47 and with a view to ensuring sufficiently informed strategies …
---------+49. Institutions should have a comprehensive understanding of their business model, strategic …
------+5.3 Risk appetite
---------+50. Institutions should ensure that their risk appetite clearly defines and addresses ESG risks …
---------+51. The risk appetite should be implemented with the support of ESG-related KRIs, including e.g. …
---------+52. Institutions should ensure that all relevant group entities and business lines and units …
---------+53. The institution’s risk appetite and associated KRIs should be subject to monitoring and …
------+5.4 Internal culture, capabilities and controls
---------+54. Institutions should develop on an ongoing basis their capabilities to identify, assess …
---------+55. The sound and consistent risk culture that accounts for ESG risks implemented within the …
---------+56. For the purposes of Title V of the EBA Guidelines on internal governance , institutions should …
---------+57. The first line of defence should be responsible for undertaking assessments of ESG risks …
---------+58. As part of the activities of the second line of defence: a) the risk management function should …
---------+59. As third line of defence, the internal audit function (IAF) should provide an independent …
------+5.5 Internal capital adequacy assessment process and internal liquidity adequacy assessment process
---------+60. Institutions should incorporate material ESG risks and their impacts on financial risk …
---------+61. When institutions take into account longer time horizons for the coverage of ESG risks, these …
---------+62. Institutions should use insights gained from their risk assessment methodologies, including …
---------+63. With regard to environmental risks, institutions should include in their ICAAP a …
---------+64. Institutions should incorporate material environmental risks and their impacts on liquidity in …
---------+65. Institutions should include in their ICAAP and ILAAP frameworks a description of the risk …
---------+66. When integrating ESG risks into their ICAAP and environmental risks in their ILAAP, the …
------+5.6 Policies and procedures for financial risk categories
---------+67. Institutions should understand and manage the current and potential future impact of ESG risks …
---------+68. For the purposes of integrating ESG risks into credit risk policies and procedures as set out …
---------+69. With regard to environmental risks, institutions should include in their policies and …
---------+70. With respect to market risk, institutions should consider how ESG risks could affect the value …
---------+71. With respect to liquidity and funding risk, institutions should at least consider how ESG risks …
---------+72. In addition, with regard to environmental risks, institutions should consider how these risks …
---------+73. With respect to operational risk, institutions should consider how ESG risks could affect the …
---------+74. With regard to environmental risks, institutions should: a) identify and label losses related …
---------+75. With respect to reputational risks, institutions should consider and manage the impact of ESG …
---------+76. As part of their management of conduct, litigation and reputational risks, institutions should …
---------+77. With respect to concentration risk, institutions should consider and manage the risks posed by …
------+5.7 Monitoring
---------+78. Institutions should monitor ESG risks through effective internal reporting frameworks that …
---------+79. Institutions should monitor ESG risks on a continuous basis and ensure that they maintain an …
---------+80. Institutions should set early warning indicators and thresholds and should have in place …
---------+81. Institutions should monitor a range of backward- and forward-looking ESG risk metrics and …
---------+82. SNCIs and other non-large institutions should monitor a range of indicators included under …
---------+83. Institutions should have clear and well-documented methodologies pertaining to their …
---+6. Plans in accordance with Article 76(2) of Directive 2013/36/EU
------+6.1 Overarching principles
---------+84. Plans developed in accordance with Article 76(2) of Directive 2013/36/EU are a product of the …
---------+85. Institutions should ensure that their plans address forward-looking ESG risk management aspects …
---------+86. Institutions should ensure that their plans and targets are well integrated into their business …
---------+87. In view of the institutions’ obligation to ensure that arrangements, processes and mecha-nisms …
------+6.2 Governance
---------+88. Institutions should clearly identify and allocate responsibilities for the development …
---------+89. The management body should be responsible for the approval of the plans and should oversee …
---------+90. For the purposes of integrating ESG risks across the three lines of defence in line with …
---------+91. Institutions should ensure meaningful and regular interaction and exchanges at all levels of …
---------+92. In line with Section 5.4, institutions should ensure they possess sufficient capacity …
---------+93. Institutions should have in place sound governance processes to collect, validate and aggregate …
------+6.3 Transition planning
---------+94. Institutions should understand their sensitivity to ESG risks, in particular environmental …
---------+95. For the purposes of monitoring and addressing the specific environmental risks that may stem …
---------+96. The geographical reference and granularity, such as in terms of regional breakdowns, of the …
---------+97. The range and complexity of the scenarios used by institutions should be proportionate to their …
---------+98. Institutions should ensure that scenarios and pathways used as part of their plans are …
---------+99. Institutions should establish a set of different time horizons as part of their plans which …
---------+100. Institutions should set milestones at regular time intervals to monitor and address ESG risks …
---------+101. Institutions should ensure that short-, medium- and long-term objectives and targets interact …
---------+102. The transition planning process of institutions should aim at managing material ESG risks, in …
---------+103. Institutions should use a range of metrics including forward-looking metrics to support …
---------+104. For the purposes of setting targets, institutions should use a set of metrics and indicators …
---------+105. When data needed to compute metrics and support the setting of targets is missing …
---------+106. SNCIs and other non-large institutions may rely on a smaller range of indicators for the use …
---------+107. Whilst institutions should at least use a combination of metrics related to climate-related …
------+6.4 Key contents of the plans
---------+108. Institutions should document their plans including their methodologies, assumptions …
---------+109. Large institutions should ensure that their plans include at least the following aspects: a. …
---------+110. SNCIs and other non-large institutions should include in their plans at least the aspects …
---------+111. Institutions should consider using the Annex as a supporting tool to develop and formalise …
------+6.5 Monitoring, review, and update of the plans
---------+112. Institutions should monitor the implementation of their plans using monitoring processes and …
---------+113. The monitoring framework should allow the management body to simultaneously track how ESG risk …
---------+114. Institutions should regularly, and at least every time they update their business strategy in …
---+Annex
------+a. Strategic objectives and roadmap of the plan
------+b. Targets and metrics
------+c. Governance
------+d. Implementation strategy
------+e. Engagement strategy
English - European Union - Financial Industry -

Guidelines on the management of ESG risks (EBA/GL/2025/01)

Guidelines on the management of ESG risks (EBA/GL/2025/01)

https://www.eba.europa.eu/activities/single-rulebook/regulatory-activities/sustainable-finance/guidelines-management-esg-risks – PDF

1. Overview

,
Summary Regulation
1. Compliance and reporting obligations

1. Compliance and reporting obligations

2. Subject matter, scope and definitions

2. Subject matter, scope and definitions

3. Implementation

3. Implementation

4. Reference methodology for the identification and measurement of ESG risks

4. Reference methodology for the identification and measurement of ESG risks

5. Minimum standards and reference methodology for the management and monitoring of ESG risks

5. Minimum standards and reference methodology for the management and monitoring of ESG risks

6. Plans in accordance with Article 76(2) of Directive 2013/36/EU

6. Plans in accordance with Article 76(2) of Directive 2013/36/EU

Annex

This Annex provides a supporting tool for institutions for the development of plans required under Article 76(2) of Directive 2013/36/EU as further specified by Section 6 of these guidelines. It does not introduce additional requirements but provides for each key content required by the guidelines some examples, references and potential metrics that institutions may consider as they structure and formalise their plans. Institutions may adapt the format of this common approach provided they ensure that all required key contents are included in their plans. In line with the need for consistency with other applicable requirements as per section 6.1 and in particular paragraph 85, institutions should ensure consistency of information used to comply with the guidelines with information disclosed in accordance with Directive 2013/34/EU and Commission Delegated Regulation (EU) 2023/2772.

. 6.4 Key contents of plansKey Clarifications words sub-ele-words or elements required key and the Guidelines Clarifying Key with or relevant paragraph(s) mentof the Examples of qualitative and quantitative out- References to other EU content puts and their potential supporting metrics frameworks reference to Potential Output Potential Output Pillar 3 CSRD / ESRS (Qualitative) (Quantitative) How to read this tool? guidance Quantitative description Links towards Pillar 3 and ESRS reference to the Qualitative description of potential output re- requirements that institutions, section(s) or of potential output re- lated to this Guidelines' where applicable, should con- of the lated to this Guide- requirement: sider to ensure consistency and Guidelines lines' requirement: - With examples or interconnections and rely to the

Direct extract from section 6.4, - With examples or ‘ warnings ’ in using met- extent possible on materially

paragraph 109 of the GuidelinesKeywords sub-ele-Key Clarifying or with relevant ment paragraph(s) words or elements content‘ do not forgets ’ , rics and targets, identical or significantly compa-guidance - For example, narra- - For example, recalling rable relevant information. reference to the tives characteristics. the different angles a KPI section(s) or could cover. References to Pillar 3 and ESRS of the All examples are for il- All examples of KPIs / may need to be updated to re-Guidelines lustration only. KRIs are for illustration flect future regulatory develop-only. ments. of the required key Examples of qualitative and quantitative out- References to other EU puts and their potential supporting metrics frameworks
6.4 Key contents of plansClarificationsandreference to the Guide- Potential Output (Qual- Potential Output Pillar 3 CSRD / ESRS lines itative) (Quantitative)

1.1 References

1.2 Identified Requirements

1.3 Related Standards

2. Identified Requirements

Requirements
Source Requirement

3. Related Standards

Standards
Source Requirement
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