Optional Disclosure Templates

Guidance for periodic disclosures for issuers of bonds marketed as environmentally sustainable or of sustainability-linked bonds

The EUGB Regulation makes provision for optional sustainability disclosure templates to facilitate comparison and address greenwashing. These templates can be used for both bonds marketed as environmentally sustainable and for sustainability-linked bonds.

Pre-issuance disclosures:

Article 20 caters for pre-issuance disclosures for issuers of bonds marketed as environmentally sustainable or of sustainability-linked bonds.

Issuers wishing to use these optional templates should take note of the Communication from the Commission establishing guidelines for pre-issuance disclosure templates for issuers of bonds marketed as environmentally sustainable or of sustainability-linked bonds.

Issuers who decide to use these templates should include relevant optional disclosures in the relevant prospectus (in those cases where they are required to issue a prospectus under the Prospectus Regulation).

Post-issuance disclosures:

Article 21 of the EUGB Regulation requires issuers of bonds marketed as environmentally sustainable and of sustainability-linked bonds to make periodic disclosures of post-issuance information by means of common templates.

The European Commission has adopted Commission Delegated Regulation (EU) 2025/753 supplementing Regulation (EU) 2023/2631 of the European Parliament and of the Council by establishing the content, methodologies, and presentation of the information to be voluntarily disclosed by issuers of bonds marketed as environmentally sustainable or of sustainability-linked bonds in the templates for periodic post-issuance disclosures. 

Common templates have been published in the Commission Delegated Regulation to cater for these disclosures. Issuers shall disclose the information referred to in Article 21, using the templates referred to in Article 1, on their website.

Issuers are required, by Regulation 24(2)  S.I. No. 41/2025 - European Union (European Green Bonds Standards and Disclosures) Regulations 2025, to notify the Central Bank without undue delay if they will be complying with this voluntary regime. The contact point for these notifications is [email protected].