The European Banking Authority (EBA) this week launched a public consultation on proposed revisions to its guidelines on product oversight and governance (POG) arrangements for retail banking products.
The revised guidelines aim to prevent greenwashing and ensure that financial institutions meet the highest standards of business conduct when offering products with Environmental, Social and Governance (ESG) features to consumers.
According to the announcement, the consultation will remain open until October 9, 2025.
The EBA stated that the proposed amendments are designed to clarify existing POG requirements for products with ESG features in a way that avoids imposing additional regulatory burdens on financial institutions.
“The aim is to prevent consumer detriment such as risks of misleading commercial practices or mis-selling of products that might occur if financial institutions fail to comply with conduct requirements when offering products with ESG features,” the authority said.
The move follows a report published by the EBA in June 2024, which highlighted a rise in potential greenwashing cases across all sectors, including among European Union banks.
The EBA explained that, in light of this report and recent legislative changes including amendments to the Capital Requirements Directive (CRD) and the Capital Requirements Regulation (CRR) concerning ESG risks, it had concluded that additional attention must be given to ESG-related products and the associated greenwashing risks in the POG Guidelines.
The consultation paper outlined a targeted approach that involves adjusting a limited number of existing POG requirements.
These include provisions related to the subject matter, the manufacturer’s internal control functions, the target market, distribution channels, information for distributors, and the information and support arrangements for manufacturers.
Moreover, the EBA said that it plans to publish the final version of the revised guidelines in the first quarter of 2026.
These guidelines, the EBA said, will then be applied as of December 1, 2026.
Comments on the consultation can be submitted via the EBA’s consultation page using the “send your comments” button. The deadline for submissions is October 9, 2025.
What is more, the EBA confirmed that all responses will be published at the end of the consultation period unless otherwise requested.
A virtual public hearing on the consultation paper will be held on September 11, 2025 between 14:30 and 16:30 CET.
Interested participants are required to register by 8 September 2025 at 17:00 CET. Dial-in details will be shared with registered attendees in advance of the event.
The EBA originally issued its POG Guidelines in 2016 to address conduct failures in financial institutions.
These guidelines are directed at manufacturers and distributors of retail banking products under the EBA’s remit, including mortgages, personal loans, deposits, payment accounts, payment services, and electronic money.
Recent legislative developments have prompted a need to revise the guidelines to integrate ESG objectives and address greenwashing risks.
“The goal is to ensure compliance with the highest standards of business conduct,” the EBA said.
The draft guidelines were developed under Article 16 of Regulation (EU) No 1093/2010.
This regulation empowers the EBA to issue guidelines to ensure effective and consistent application of European Union law.
