National central banks in the European Union are part of the European banking supervision system under the Single Supervisory Mechanism (SSM), which includes the European Central Bank (ECB) and the national supervisory authorities of member countries. The ECB focuses on the Significant Institutions (SIs) by regularly assessing their financial situation, verifying their compliance with prudential requirements, taking any necessary supervisory measures, and performing stress tests. Less Significant Institutions (LSIs) are supervised directly by the national central banks, which provide harmonised supervision guided by the general policies and instructions issued by the ECB. In 2022, SIs of the member countries participated in the ECB Thematic Review on institutions’ climate-related and environmental risk strategies, as well as their governance and risk management frameworks and processes. The ECB Thematic Review was conducted by the ECB and 21 national competent authorities and covered 186 banks. In 2023, the ECB reviewed practices and trends of climate-related and environmental risk disclosure of 103 SIs and 28 LSIs in the Eurozone. The assessment covered the existence, substantiation and soundness of disclosures across key areas of the supervision expectations, including materiality assessment, business model and strategy, governance, risk management, and metrics and targets. The information typically considered in the assessment included: annual reports, non-financial reports, sustainability reports and EBA Pillar 3 reports. For consistency with other supervisory exercises performed in 2022, the ECB also considered the documents submitted by the institutions in the context of its 2022 ECB Thematic Review on climate-related and environmental risks and the 2022 climate risk stress test.
Since 2025, the ECB’s remit includes the supervision of transition plans developed by European banks in the context of the implementation of the Basel reforms. Under the new prudential framework, European banks will be required to submit their transition plans, which will include specific objectives and targets for the transition to a sustainable economy.
In parallel, European banks and financial intermediaries are subject to disclosing ESG information in the EBA Pillar 3 templates, as well as under the TCFD principles and recommendations. In 2023, large institutions with listed securities published the first set of annual disclosures on ESG risks under EBA’s Pillar 3 disclosure requirements. Notably, the European Banking Authority (EBA) requires banks to disclose exposures to carbon-intensive activities and assets that may experience physical risk as a result of climate change, financed emissions data and alignment of metrics with 2050 net-zero goals.
In the scope of the European Commission’s Renewed Sustainable Finance Strategy, the EBA conducts the one-off Fit-for-55 climate risk scenario analysis in collaboration with the other European Supervisory Authorities (ESAs), the ECB and the European Systemic Risk Board (ESRB). The exercise aims at assessing the resilience of the financial sector in line with the Fit-for-55 package, and to gain insights into the capacity of the financial system to support the transition to a lower carbon economy under conditions of stress. In November 2025, the EBA published the Guidelines on environmental scenario analysis on the management of ESG risks. The Guidelines aim to support institutions in developing their internal capabilities and skills necessary for setting and using scenarios, primarily to test the shock-absorbing capacity of their capital and liquidity reserves as well as the resilience of their business model over the medium to long-term (European Banking Authority, 2025[16]).
At the funds level, the European Insurance and Occupational Pensions Authority (EIOPA) published an opinion on sustainability claims alongside its final report on greenwashing in April 2024. The opinion, setting out a series of principles applicable at product- and entity-level, requires providers to substantiate claims related to longer-term sustainability objectives, such as transition plans or commitments, with detailed plans, interim targets and regular reporting on the implementation status of their plans. The EIOPA plans to monitor supervisory actions taken by competent authorities starting in 2026.
The European Securities and Markets Authority (ESMA) published a similar report in June 2024. The report examines the current supervisory framework for monitoring greenwashing risks and sets out an agenda for ESMA and national competent authorities to follow going forward. Specifically, ESMA committed to fostering supervisory convergence by introducing common strategic supervisory priorities and actions focusing on sustainability-related disclosures. Further, ESMA plans to develop indicators to monitor greenwashing risk, support the deployment of supervisory tools, and provide additional guidance in high-risk greenwashing areas.