With EU Delegated Regulation 2025/753, EU Adopts New Standardized Reporting Framework for Sustainable Bonds

Luxembourg Financial Regulatory News:

The Commission Delegated Regulation (EU) 2025/753 in Luxembourg, which supplements Regulation (EU) 2023/2631 of the European Parliament and of the Council, concerns the bonds marketed as environmentally sustainable or sustainability-linked. The regulation establishes content, methodologies, and presentation standards for the voluntary post-issuance disclosure of information by issuers of these types of bonds. It outlines specific templates for disclosure, specifying details such as general information, environmental strategy, allocation of proceeds, environmental impact, and reporting information. The text further details requirements for the frequency of disclosure, publication on websites, correction procedures, and notification to competent authorities, all aimed at enhancing transparency and standardization in the sustainable bond market.

Read more about Commission Delegated Regulation (EU) 2025/753 in Luxembourg, which supplements Regulation (EU) 2023/2631 at the official link at https://www.cssf.lu/en/Document/commission-delegated-regulation-eu-2025-753-of-16-april-2025/

Commission Delegated Regulation (EU) 2025/753 in Luxembourg represents a significant step towards standardizing and increasing transparency in the voluntary post-issuance disclosure for environmentally sustainable and sustainability-linked bonds within the EU. While the use of the templates remains voluntary, opting into their use commits issuers to follow a prescribed structure and methodology, providing investors with more consistent and comparable data. The detailed requirements for reporting frequency, publication, corrections, and notification to competent authorities underscore the EU’s commitment to mitigating greenwashing risks and fostering a robust sustainable finance market.

The following article summarizes the key provisions of Commission Delegated Regulation (EU) 2025/753 in Luxembourg, which supplements Regulation (EU) 2023/2631 by establishing common templates for voluntary post-issuance disclosures by issuers of bonds marketed as environmentally sustainable or sustainability-linked bonds. The aim is to enhance transparency and standardization in the sustainable bond market.

Key Themes and Important Ideas/Facts of Commission Delegated Regulation (EU) 2025/753 in Luxembourg:

1. Voluntary Nature of Disclosure, but Standardized if Chosen:

• Issuers of bonds marketed as environmentally sustainable and sustainability-linked bonds are not obligated to disclose information using these common templates.
• However, if they choose to use them, they “should follow them.”
• Issuers retain the freedom to disclose “additional information” beyond the templates.
• The regulation explicitly states: “There is no obligation to disclose the information referred to in Article 21 of Regulation (EU) 2023/2631 using these common templates. However, if issuers opt for using those templates, they should follow them.” (Whereas 1)

2. Enhancing Transparency and Comparability:

• The primary objective is to “facilitate the use of the information contained in those templates by investors and thus increase transparency.” (Whereas 2)
• The templates are designed to ensure “consistency between and comparability” of voluntary post-issuance disclosures with pre-issuance disclosures and existing European Green Bond Standard requirements. (Whereas 2, 3)
• Providing clarity on template usage is expected to “encourage take-up of those templates, thus helping to enhance transparency and standardisation in the market for sustainable bonds.” (Whereas 4)

3. Scope and Application under Commission Delegated Regulation (EU) 2025/753 in Luxembourg:

• The regulation applies to “issuers of bonds marketed as environmentally sustainable or of sustainability-linked bonds that choose to use the common voluntary templates referred to in Article 21(1) of Regulation (EU) 2023/2631.” (Article 1)
• The templates are provided in an Annex, with distinct sections for environmentally sustainable bonds and sustainability-linked bonds.

4. Disclosure Frequency and Timelines:

• Environmentally Sustainable Bonds: Disclosures are required “for each 12-month period until the date of full allocation of the proceeds of those bonds.” (Article 2(1))
• Sustainability-Linked Bonds: Disclosures are required “for each 12-month period until the last sustainability-target observation.” (Article 2(1))
• The first 12-month period begins on the bond’s issuance date. (Article 2(2))
• Issuers can choose the end date of the first reporting period to align with their calendar or financial year. (Article 2(3))
• External Review Impact:With external review: disclosures must be made “within 270 days of the end of every 12-month period.” (Article 2(4))
• Without external review: disclosures must be made “within 150 days of the end of every 12-month period.” (Article 2(5))

5. Publication Requirements under Commission Delegated Regulation (EU) 2025/753 in Luxembourg:

• Disclosures must be published “on their website.” (Article 3(1))
• Information, including amendments or corrections, must remain “available, free of charge, until at least 12 months after the maturity of the bonds concerned.” (Article 3(1))
• Language: Issuers can choose a language customary in international finance, or the language(s) accepted by the competent authority of the Member State(s) where the bonds are offered/traded. If a prospectus exists, the language(s) of the prospectus must be used. (Article 3(2), (3))

6. Corrections and Updates under Commission Delegated Regulation (EU) 2025/753 in Luxembourg:

• If the “allocation of proceeds is corrected after the publication,” issuers “shall immediately update that information accordingly and publish it without undue delay.” (Article 4)

7. Notification to Competent Authorities under Commission Delegated Regulation (EU) 2025/753 in Luxembourg:

• Issuers must “by electronic means and without undue delay after each publication,” notify competent authorities of:
• The publication of disclosures.
• The publication of any updates.
• The hyperlink to the website where the information is published. (Article 5(1))
• Competent authorities are required to “create a contact point” for these notifications. (Article 5(2))

8. Content of the Templates (Annex Overview):

• General Information (Both Bond Types): Date of issuance/publication, reporting period, issuer’s legal name and LEI, contact website, bond-related documents website, bond name, ISIN, external reviewer details (if applicable), competent authority for prospectus (if applicable).
• Environmentally Sustainable Bonds Specifics: Environmental Strategy and Rationale: Environmental objectives (per Regulation (EU) 2020/852), link to taxonomy-alignment (turnover, CapEx, OpEx) for issuers subject to Article 8 of Regulation (EU) 2020/852, and contribution to transition plans.
• Allocation of Bond Proceeds: Whether proceeds are allocated gradually or to a portfolio, proportion used for “environmentally sustainable under Article 3 of Regulation (EU) 2020/852,” and specific details for sovereign issuers. Includes two tables (Table A for gradual allocation, Table B for portfolio) requiring granular data on projects, taxonomy-alignment, environmental objectives, and types of expenditure.
• Exclusions: A “yes/no” statement if the bond excludes activities referred to in Commission Delegated Regulation (EU) 2020/1818.
• (Optional) Environmental Impact: Description of environmental impacts, including specific metrics (e.g., GHG emissions avoided, renewable energy capacity).
• Sustainability-Linked Bonds Specifics: Important Characteristics of the Bond: Rationale and ambition level, materiality and calculation methodology of Key Performance Indicators (KPIs) and Sustainability Performance Targets (SPTs), progress updates, statement on external review of KPIs, link to taxonomy-aligned metrics (per Regulation (EU) 2021/2178), and bond structure details (e.g., coupon adjustment).
• Environmental Strategy and Rationale: Environmental objectives (per Regulation (EU) 2020/852) and contribution to transition plans.
• Information on Reporting (Both Bond Types): Link to issuer’s website and relevant reports (e.g., consolidated management/sustainability report).
• Other Relevant Information (Both Bond Types): Placeholder for additional relevant information.

9. Legal Basis and Entry into Force of Commission Delegated Regulation (EU) 2025/753 in Luxembourg:

• The Regulation is adopted having regard to the Treaty on the Functioning of the European Union and specifically Article 21(4) of Regulation (EU) 2023/2631.
• It entered into force on the twentieth day following its publication in the Official Journal of the European Union.
• “This Regulation shall be binding in its entirety and directly applicable in all Member States.”

Timeline of Main Events related to Commission Delegated Regulation (EU) 2025/753

• June 26, 2013: Directive 2013/34/EU of the European Parliament and of the Council on annual financial statements, consolidated financial statements, and related reports of certain types of undertakings is adopted. This Directive is referenced multiple times as establishing obligations for issuers to publish certain plans.
• June 14, 2017: Regulation (EU) 2017/1129 of the European Parliament and the Council on the prospectus to be published when securities are offered to the public or admitted to trading on a regulated market is adopted. This regulation is relevant for determining the language of disclosures if a prospectus has been published.
• June 18, 2020: Regulation (EU) 2020/852 of the European Parliament and of the Council (the “Taxonomy Regulation”) is adopted. This regulation establishes a framework to facilitate sustainable investment and defines environmental objectives and criteria for environmentally sustainable economic activities, which are central to the disclosures for environmentally sustainable bonds.
• July 17, 2020: Commission Delegated Regulation (EU) 2020/1818 is adopted, supplementing Regulation (EU) 2016/1011 as regards minimum standards for EU Climate Transition Benchmarks and EU Paris-aligned Benchmarks. This regulation defines activities that may be excluded from bond proceeds allocation.
• July 6, 2021: Commission Delegated Regulation (EU) 2021/2178 is adopted, supplementing Regulation (EU) 2020/852. This regulation specifies the content and presentation of information to be disclosed by undertakings concerning environmentally sustainable economic activities and the methodology for compliance.
• November 22, 2023: Regulation (EU) 2023/2631 of the European Parliament and of the Council on European Green Bonds and optional disclosures for bonds marketed as environmentally sustainable and for sustainability-linked bonds is adopted. This foundational regulation mandates the Commission to publish guidelines for pre-issuance disclosures (Article 20) and allows for voluntary post-issuance disclosures using common templates (Article 21). Article 45 enables competent authorities to require inclusion of certain elements in these templates.
• April 16, 2025: The European Commission adopts Commission Delegated Regulation (EU) 2025/753. This Regulation supplements Regulation (EU) 2023/2631 by establishing the content, methodologies, and presentation of information to be voluntarily disclosed by issuers of environmentally sustainable or sustainability-linked bonds in templates for periodic post-issuance disclosures. Ursula von der Leyen, as President of the Commission, signs this regulation.
• July 25, 2025: Commission Delegated Regulation (EU) 2025/753 is published in the Official Journal of the European Union (OJ L, 2025/753).
• August 14, 2025 (approx.): Commission Delegated Regulation (EU) 2025/753 enters into force on the twentieth day following its publication in the Official Journal.

Ongoing/Post-Entry into Force:

• After August 14, 2025: Issuers of bonds marketed as environmentally sustainable or sustainability-linked bonds may choose to use the common voluntary templates for periodic post-issuance disclosures.
• If using templates, issuers of environmentally sustainable bonds disclose annually until full allocation of proceeds.
• If using templates, issuers of sustainability-linked bonds disclose annually until the last sustainability-target observation.
• Issuers with an external review must disclose within 270 days of the 12-month period end.
• Issuers without an external review must disclose within 150 days of the 12-month period end.
• Disclosures must be published on the issuer’s website, free of charge, and remain available for at least 12 months after bond maturity.
• Issuers must notify competent authorities electronically of any publications or corrections, providing a hyperlink.
• Competent authorities are required to create a contact point for these notifications.
• Issuers must immediately update and republish information if proceed allocation is corrected.

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The pre-filled example templates for multiple CSSF Circulars and EU regulations applicable to small to medium sized financial institutions in Luxembourg should be available at https://ratiofy.lu/templates/ from Christmas 2025.