Circulaire NBB_2025_11 / EBA Guidelines of 8 January 2025 on Environmental, Social and Governance Risk Management (EBA/GL/2025/01)

Public NBB_2025_11 – 8 October 2025 Circular – Page 1/2 Boulevard de Berlaimont 14 – 1000 Brussels tel. +32 2 221 38 12 company number: 0203.201.340 RPM Brussels www.nbb.be Circular Public Brussels, 8 October 2025 Reference: NBB_2025_11 Your contact:
Brenda Van Tendeloo tel. +32 2 221 51 74
Brenda.vantendeloo@nbb.be

EBA Guidelines of 8 January 2025 on Environmental, Social and Governance Risk Management (EBA/GL/2025/01)

Scope

• Credit institutions, financial services groups and mixed financial holding companies under Belgian law;
• Large investment firms under Belgian law referred to in Article 1, paragraphs 2 and 5, of Regulation 2019/2033;
• Investment holding companies and mixed financial holding companies under Belgian law included in consolidated supervision by the National Bank of Belgium, where such a group includes a large investment firm;
  Hereinafter referred to as "the institutions".

This circular clarifies the NBB's approach towards less significant institutions (LSI). It is recommended that significant institutions (SI) subject to direct supervision by the ECB follow this circular to the extent that the ECB does not publish guidelines in this regard.

Summary/Objectives
This circular aims to implement the guidelines of the European Banking Authority (EBA) of 8 January 2025 on Environmental, Social and Governance Risk Management (EBA/GL/2025/01) (hereinafter "the EBA Guidelines"). The French version of the text established by the EBA can be found on the website of the National Bank of Belgium.

National Bank of Belgium
Eurosystem

Public NBB_2025_11 – 8 October 2025 Circular – Page 2/2

Madam,
Sir,

ESG risks, and in particular environmental risks, can have a significant impact on the safety and soundness of financial institutions. Both physical and transition risks can influence traditional financial risks such as credit risk, market risk, liquidity risk and operational risk. The EBA Guidelines attached to this circular specify the internal processes and ESG risk management arrangements that institutions must put in place in accordance with the Capital Requirements Directive (CRD VI).

The guidelines cover the identification, measurement, control and monitoring of ESG risks and also include guidelines relating to the plans provided for in Article 76, paragraph 2, of Directive 2013/36/EU (CRD VI) aimed at ensuring the resilience of institutions to ESG risks in the short, medium and long term.

The guidelines take into account proportionality, both in terms of the materiality of the risks and those of the size and complexity of the institutions. Small and non-complex institutions1 as well as other institutions that are not considered large2, must collect and monitor less data and indicators and may rely on simplified methodologies and assumptions, both for day-to-day risk management and for scenario analyses and prudential plans referred to in Article 76, paragraph 2, of the CRD VI.

These guidelines will apply from 11 January 2026, except for small and non-complex institutions, for which they will enter into force no later than from 11 January 2027.

A copy of this circular is sent to the approved auditor(s) of your company.

Please accept, Madam, Sir, the assurance of my distinguished consideration.

Pierre Wunsch
Governor

Appendix: 1
EBA Guidelines of 8 January 2025 on Environmental, Social and Governance (ESG) Risk Management (EBA/GL/2025/01)

1 As defined in Article 4, paragraph 1, point 145, of the CRR.
2 As defined in Article 4, paragraph 1, point 146, of the CRR.