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Only 41% of EU banks have published their transition plans under the corporate sustainability reporting directive (CSRD), despite being required to do so, while very few have a Paris-aligned pathway, according to a new report from Finance Watch.
The analysis of 64 of the biggest banks in Europe, covering 75% of EU banking assets, has found that some institutions only have plans with a limited scope of activities or exposures, “creating uncertainty about whether all material exposures are considered”.
While 86% of banks have emissions reduction targets, only 59% disclosed their transition plans, highlighting the ambiguity around the CSRD’s transition plan requirement, the report says.
There is also a lot of confusion about what constitutes a transition plan under the CSRD, said Vincent Vandeloise, senior researcher at Finance Watch.
“We see that there is confusion already on what is actually a CSRD transition plan and how the information has to be provided, and that leaves some confusion and difficulties as well to read the transition plans the way they are being released,” he said.
Some banks have transition plans that are aligned with scenarios beyond a warming of 2°C, while others are aligned with 1.5°C.
Vandeloise says banks that have emission reduction targets should disclose their transition plans and say to what degree they are aligned with the Paris Agreement. Disclosing the underlying ambition will offer “additional data for the investors to know what they’re investing into and to assess the underlying risk,” he said.
There is an issue of comparability. Transition plans were submitted in various formats which can make them difficult to assess and compare, said Vandeloise. Some are in free text format, while others have graphs and are formatted so they are much easier to read, making it difficult to compare banks and identify the most ambitious companies.
While changes to the CSRD are expected under the EU’s sustainable omnibus proposal, the banks reviewed will likely fall under the scope of the directive. Already, 91% of banks that Finance Watch analysed have submitted CSRD reports even though some jurisdictions have yet to transpose the directive into national law.
Most of the banks that have not reported are based in Germany, which has had a strong role in shaping the EU omnibus proposals which, if accepted, will lower the scope of companies subject to CSRD.
This page was last updated November 12, 2025
Written by
Moriah Costa is the Editor-in-Chief of Green Central Banking and has over a decade of experience writing about banking and finance. She is an award-winning American journalist based in Paris and has written for major international publications, including Reuters, The Guardian, and S&P Global. Having grown up in water-stressed Arizona, she has always had a strong interest in bringing awareness to climate and environmental issues.
