CRR3 Pillar 3 disclosure: the new EU SB1 template is the visible change, the deleted templates are the bigger problem

The new shadow-banking template is the visible change in EBA's 22 June 2026 final draft ITS (EBA/ITS/2026/02). The deletions are where most reporting teams will trip. A bank that builds its 31 December 2026 Pillar 3 disclosure off last year's mapping will still be populating the Green Asset Ratio tables, still chasing top-20 carbon-intensive counterparty data, and still wiring cross-references to the Taxonomy delegated act. None of that survives the amending ITS.

Three CRR3 changes converge in one instrument. Article 449a ESG disclosure is rebuilt and extended to more institutions. Article 438(e) equity disclosure is simplified to a single total in EU CR 10.5, with voluntary early adoption permitted. And a new Article 449b disclosure on aggregate exposure to shadow banking entities arrives with its own template, EU SB1, reusing LE3-style data from the large-exposures returns.

Worth flagging on the ESG side:

- Templates 4 and 6 to 9 are deleted (top-20 carbon, GAR, BTAR).

- Template 10 survives but is rescoped to cover all climate-risk-mitigating exposures, not just taxonomy-aligned ones.

- Template 1.1 is retained as the SNCI minimum.

- EU CQ5 moves to NACE Rev. 2.1; a stale NACE mapping will pass footing checks while still being wrong at the sector level.

- ESG scope is three tiers under amended Article 22 of 2024/3172 (large; other listed plus large subsidiaries; SNCI and other non-listed). The simplified set is not the large-institution set with rows hidden; the populations differ in substance.

Dates are where confident-sounding plans go wrong. The general ESG reference date is 31 December 2026. SNCIs and institutions subject to Article 433b(1)(f) should plan on 31 December 2027. The ITS application date and the disclosure reference date are different concepts, and the reference date is what tells you which balance-sheet snapshot you actually report. Track them in separate fields.

One sequencing point worth getting right: the August 2025 EBA no-action letter on Templates 6 to 10 is interim forbearance, not the binding standard. From the 31 December 2026 reference date, the amending ITS governs and Templates 6 to 9 are gone for good. Do not let a build scoped around the no-action letter quietly become the go-live build.

Source basis: Regulation (EU) 2024/1623 (CRR3) Articles 438(e), 449a and 449b; Commission Implementing Regulation (EU) 2024/3172; Commission Delegated Regulation (EU) 2023/2779; EBA/ITS/2026/02 Final Report (22 June 2026).

Full article: https://regreportingdesk.com/crr3-pillar-3-disclosure-esg-equity-shadow-banking-eba-its/