Circular CSSF 26/905 is a CSSF circular, published 20 January 2026. Subject: Application of the Guidelines of the European Banking Authority on the management of environmental, social and governance (ESG) risks (EBA/GL/2025/01).
\nRelevant for: Credit institutions.
\nMain topic: Sustainable finance. Keywords: Risk management.
\nCircular CSSF 26/905 Application of the Guidelines of the European Banking Authority on the management of environmental, social and governance (ESG) risks (EBA/GL/2025/01)
\nCircular CSSF 26/905 Application of the Guidelines of the European Banking Authority on the management of environmental, social and governance (ESG) risks (EBA/GL/2025/01) To all credit institutions designated as Less Significant Institutions 1 under the Single Supervisory Mechanism.
\nLuxembourg, 20 January 2026 Ladies and Gentlemen, The purpose of this circular is to inform you that the CSSF, in its capacity as competent authority, applies the Guidelines (EBA/GL/2025/01) of the European Banking Authority (the “EBA”) on the management of environmental, social and governance (ESG) risks (the “Guidelines”), published on 8 January 2025. Consequently, the CSSF has integrated the Guidelines into its administrative practice and regulatory approach with a view to promoting supervisory convergence in this field at the European level.
\nThe Guidelines The Guidelines specify the requirements regarding the internal processes and ESG risk management arrangements institutions need to have in place in accordance with Articles 87a, 76 and 74 of the amended Directive 2013/36/EU 2. The Guidelines set out requirements for institutions for the identification, measurement, management and monitoring of ESG risks, including through plans aimed at addressing the risks arising from the transition towards an EU climate-neutral economy. The Guidelines are attached to this circular (see Annex I) and are available on the EBA’s website 3.
\nScope of application This circular shall apply to Less Significant Institutions. Small and non-complex institutions (SNCIs) 4 as well as other non-large institutions may apply the proportionality provisions presented in the Guidelines, where appropriate, allowing them to implement less complex or sophisticated arrangements.
\n“Significant supervised entities” as defined in point (16) of Article 2 of Regulation (EU) No 468/2014 of the European Central Bank (ECB) of 16 April 2014 (the SSM Framework Regulation) shall refer to the relevant ECB rules.
\n2 Directive 2013/36/EU of the European Parliament and of the Council of 26 June 2013 on access to the activity of credit institutions and the prudential supervision of credit institutions, amending Directive 2002/87/EC and repealing Directives 2006/48/EC and 2006/49/EC 3
\nEBA/GL/2025/01- ESG Risk Management Guidelines
\nSmall and Non-Complex Institutions as defined in point (145) of Article 4(1) of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions. 4
\nDate of application This circular shall apply from 1 April 2026 to Less Significant Institutions other than SNCIs. It will apply from 11 January 2027 to SNCIs.
\nAmendment of Circular CSSF 21/773 This circular amends Circular CSSF 21/773 on the Management of Climate-related and Environmental Risks which remains applicable to SNCIs until 10 January 2027 and to third-country branches 5. Annex II provides a version of Circular CSSF 21/773 showing the changes implemented. Annex III presents a timeline of the entry into application of the Guidelines and/or the application of Circular CSSF 21/773 per type of institutions for the years 2026 and 2027.
\nAnnexes
\nEBA
\nGuidelines
\n(EBA/GL/2025/01)
\nthe
\nmanagement
\nenvironmental, social and governance (ESG) risks II.
\nIII.
\nThe text above is the opening of the document; the PDF carries the whole.
\nDocument page, PDF. Source: Commission de Surveillance du Secteur Financier (CSSF), reproduced with the CSSF's consent. The French text prevails.
"}