Comments on EBA Discussion Paper on management and supervision of ESG risks for credit institutions and investment firms

The German Banking Industry Committee (GBIC) has submitted its comments to the public consultation of the European Banking Authority (EBA) on the Discussion Paper on management and supervision of ESG risks for credit institutions and investment firms. In general, GBIC welcomes EBA's commitment to establish a unified European framework with uniform definitions regarding the topic of ESG.

Furthermore, GBIC supports EBA's approach of initially covering this area via a discussion paper, then obtaining feedback from industry and, based on this, drafting a report which influences or adapts the existing regulatory requrements, or results in new ones. From the point of view of GBIC, the principle of proportionality as a fundamental principle in Pillar II should be more firmly anchored in the paper. It should be also be taken into account that many institutions are still engaged in analysing the ESG issue and are still at the beginning of many developments. GBIC therefore recommends a gradual introduction of regulatory requirements.