Public consultation proposing to revise the EBA Guidelines on product oversight and governance arrangements for retail banking products
The European Banking Authority (EBA) today launched a public consultation proposing to revise the EBA Guidelines on product oversight and governance (POG) arrangements for retail banking products. The proposed revision aims 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. The consultation runs until 9 October 2025.
The proposed amendments aim to strike the right balance between clarifying existing POG requirements for products with ESG features to prevent consumer detriment (e.g. risks of misleading commercial practices, mis-selling of products etc.) that might occur if financial institutions fail to comply with conduct requirements when offering product with ESG features, without imposing additional regulatory burden on FIs.
In June 2024, the EBA published a report on greenwashing, highlighting an increase in potential cases across all sectors, including among EU banks. In light of this report and recent legislative changes such as amendments to the Capital Requirement Directive (CRD) and the Capital Requirements Regulation (CRR) regarding ESG risks, the EBA concluded that it is necessary to give further consideration to products with ESG features and greenwashing risks in the existing POG Guidelines.
The consultation paper proposes a targeted approach, adjusting only a limited number of existing requirements in the POG GLs related to the subject matter, manufacturer’s internal control functions, the target market, distribution channels, information for distributors and information and support for the manufacturer’s arrangements.
The EBA expects to publish its final guidelines in Q1 2026, which will be applied as of 1 December 2026.
Consultation process and next steps
Comments to this consultation can be sent to the EBA by clicking on the „send your comments” button on the consultation page. Please note that the deadline for the submission of comments is 9 October 2025. All received contributions will be published at the end of the consultation, unless requested otherwise.
The EBA will hold a virtual public hearing on the consultation paper on 11 September 2025 from 14:30 to 16:30 CET. Please register for the hearing here by 8 September 2025 by 17:00 CET. The dial-in details will be communicated to those who have registered for the meeting.
Background
The EBA issued its initial POG Guidelines in 2016 to address conduct failures of financial institutions. These Guidelines are addressed to manufacturers and distributors of retail banking products in EBA’s remit, namely mortgages, personal loans, deposits, payment accounts, payment services, and electronic money. Recent legislative developments necessitate a revision to incorporate ESG objectives and greenwashing risks and to ensure compliance with the highest standards of business conduct.
The EBA developed these draft Guidelines in accordance with Article 16 of Regulation (EU) No 1093/2010 which empowers the EBA to issue guidelines to ensure the effective and consistent application of European Union law.
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Documents
Consultation paper on draft revised Guidelines on product oversight and governance – (430.88 KB – PDF) Download
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Guidelines on product oversight and governance arrangements for retail banking products
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