Home Europe European Commission Commission Implementing Regulation (EU) 2025/2179 of 12 Sept...
Date: 2025-12-30 Category: Not Applicable State: Union Government Country: Europe

Commission Implementing Regulation (EU) 2025/2179 of 12 September 2025 laying down implementing technical standards for the application of Regulation (EU) 2023/2631 of the European Parliament and of the Council with regard to the standard forms, templates, and procedures for the provision of the information for an application for registration as an external reviewer for European Green Bonds

Issued by European Commission · Directorate-General for Financial Stability

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Executive Summary & Key Takeaways

**Executive Summary** Commission Implementing Regulation (EU) 2025/2179, dated 12 September 2025, establishes implementing technical standards for Regulation (EU) 2023/2631 concerning the standard forms, templates, and procedures for providing information in an application for registration as an external reviewer for European Green Bonds. It mandates machine-readable formats for application submissions and requires a signed attestation letter from senior management. The regulation enters into force twenty days after its publication in the Official Journal of the European Union. **Key Points / Main Content** * **Format of Information:** * Applicants must submit information as per Article 23(1) of Regulation (EU) 2023/2631, adhering to the format outlined in the Annexes of this Regulation. * Information must be provided in a machine-readable format, ensuring accessibility and unchanged reproducibility. * **Document Submission Requirements:** * Applicants must assign a unique reference number to each submitted document. * Submitted documents must clearly indicate the specific requirement of Regulation (EU) 2023/2631 to which they refer and the document containing the information. * Applicants must submit a completed table as per Annex I, clearly identifying the location of required information within the submitted documents. * If a requirement of Regulation (EU) 2023/2631 does not apply, this should be stated in the table provided in the Annex, along with an explanation. * Applications must include a letter signed by a member of senior management attesting to the accuracy and completeness of the submitted information as of the submission date. * **Data Retention:** * External reviewers and ESMA must retain personal data relating to applicants for no more than five years after the applicant has ceased to perform its function. * If ESMA refuses registration or the applicant withdraws, personal data relating to that applicant should be kept by ESMA for no longer than five years after the refusal or withdrawal. **Impact Analysis** **Applicants for registration as external reviewers for European Green Bonds** *Impact:* * Must comply with the specified formats, templates, and procedures for submitting information to ESMA. * Must ensure data security and accessibility, provide accurate attestations, and track document references. *Action Required:* * Implement systems to generate machine-readable documents and assign unique reference numbers. * Establish processes for senior management to review and attest to the accuracy and completeness of application information. * Develop procedures for data retention and deletion in accordance with the regulation. **European Securities and Markets Authority (ESMA)** *Impact:* * Will receive applications in a standardized, machine-readable format, facilitating assessment. * Must process applications and retain data in accordance with the regulation’s requirements. *Action Required:* * Update internal processes to accommodate the standardized application format. * Establish data retention policies and procedures in compliance with the regulation.

Key Entities Referenced

Regulation (EU) 2023/2631: Regulation 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. This regulation is frequently referenced as the core legislation being implemented. European Securities and Markets Authority (ESMA): The European Securities and Markets Authority, which plays a significant role in registration and assessment processes related to external reviewers. Commission Delegated Regulation (EU) 2025/2180: A Delegated Regulation supplementing Regulation (EU) 2023/2631 with regard to regulatory technical standards specifying the conditions for the registration of external reviewers.
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Official Journal EN of the European Union L series 2025/2179 30.12.2025 COMMISSION IMPLEMENTING REGULATION(EU) 2025/2179 of 12 September 2025 laying down implementing technical standards for the application of Regulation (EU) 2023/2631 of the European Parliament and of the Council with regard to the standard forms, templates, and procedures for the provision of the information for an application for registration as an external reviewer for European Green Bonds (Text with EEA relevance) THE EUROPEAN COMMISSION, Having regard to the Treaty on the Functioning of the European Union, Having regard to Regulation (EU) 2023/2631 of the European Parliament and of the Council of 22 November 2023 on European Green Bonds and optional disclosures for bonds marketed as environmentally sustainable and for sustainability- linked bonds(1), and in particular Article 23(7), fourth subparagraph thereof, Whereas: (1) The way that information in an application for registration as an external reviewer is provided should enable the European Securities and Markets Authority (ESMA) to assess whether the conditions referred to in Article 23(2) of Regulation (EU) 2023/2631 are fulfilled, including the conditions laid down in Commission Delegated Regulation (EU) 2025/2180(2). (2) To safeguard security and enhance data management and usability, the standard forms, templates, and procedures that applicants should use when they apply for registration as an external reviewer should allow for digital means of registration. Any information that applicants submit to ESMA in an application for registration should therefore be machine-readable and be provided in a durable medium. (3) To assist ESMA in identifying the documents that an applicant has submitted as part of the application for registration, a unique reference number should be provided to correspond to each document. (4) For assurance and accountability purposes, applicants that submit an application for registration to ESMA should complement that application with a letter signed by a member of its senior management, attesting that the submitted information is accurate and complete to the best of that member’s knowledge. (5) This Regulation is based on the draft implementing technical standard submitted to the Commission by ESMA. (6) This Regulation respects the fundamental rights and observes the principles recognised by the Charter of Fundamental Rights of the European Union, and notably the right to protection of personal data. The processing of personal data for the purposes of this Regulation should be carried out in accordance with Union law on the protection of personal data. In that regard, any processing of personal data performed by ESMA in application of this Regulation should be carried out in accordance with Regulation (EU) 2018/1725 of the European Parliament (1) OJ L, 2023/2631, 30.11.2023, ELI: http://data.europa.eu/eli/reg/2023/2631/oj. (2) Commission Delegated Regulation (EU) 2025/2180 of 12 September 2025 supplementing Regulation (EU) 2023/2631 of the European Parliament and of the Council with regard to regulatory technical standards specifying the conditions for the registration of external reviewers and the criteria for assessing the sound and prudent management of external reviewers, the appropriateness of the knowledge, experience and training of the external reviewers’employees and the conditions under which external reviewers outsource their assessment activities (OJ L, 2025/2180, 30.12.2025, ELI: http://data.europa.eu/eli/reg_del/2025/2180/oj). ELI: http://data.europa.eu/eli/reg_impl/2025/2179/oj 1/10EN OJ L, 30.12.2025 and of the Council(3). Any processing of personal data performed by entities applying for external reviewer within application of this Regulation should be carried out in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council(4)and national requirements on the protection of natural persons with regard to the processing of personal data. (7) To enable ESMA to conduct the assessment for the purposes of the initial registration, while ensuring appropriate safeguards, personal data relating to applicants for registration as an external reviewer should be kept by external reviewers and ESMA for no longer than five years after that applicant has ceased to perform its function where the applicant has been registered as an external reviewer. Where ESMA has refused to register an applicant external reviewer or where the applicant withdraws its application, personal data relating to that applicant should be kept by ESMA no longer than five years after the refusal of the registration of the applicant or after the withdrawal of the application. (8) The European Data Protection Supervisor was consulted in accordance with Article 42(1) of Regulation (EU) 2018/1725 and delivered formal comments on 7 July 2025. (9) ESMA has conducted an open public consultation on the draft implementing technical standard on which this Regulation is based. It has analysed the potential related costs and benefits and requested the advice of the Securities and Markets Stakeholder Group established in accordance with Article 37 of Regulation (EU) No 1095/2010 of the European Parliament and of the Council(5), HAS ADOPTED THIS REGULATION: Article 1 Format to follow for the provision of the information referred to in Article 23(1) of Regulation (EU) 2023/2631 1. Applicants for registration as an external reviewer for European Green Bonds shall submit the information referred to in Article 23(1) of Regulation (EU) 2023/2631 in the format set out in the Annexes to this Regulation. 2. Applicants shall provide ESMA with the information referred to in Article 23(1) of Regulation (EU) 2023/2631 in a machine-readable format which: (a) allows the information to remain accessible for a period of time adequate for the purposes of the application; (b) allows for the unchanged reproduction of the information stored. 3. Applicants shall provide a unique reference number to each document that they submit to ESMA. Applicants shall ensure that the documents they submit clearly identifies to which specific requirement of Regulation (EU) 2023/2631 it refers and in which document that information is provided. Applicants shall submit the table set out in Annex I to this Regulation as part of their application and shall clearly identify the document in which they have provided the information required. (3) Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC (OJ L 295, 21.11.2018, p. 39, ELI: http://data. europa.eu/eli/reg/2018/1725/oj). (4) Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, 4.5.2016, p. 1, ELI: http://data.europa.eu/eli/reg/2016/679/oj). (5) Regulation (EU) No 1095/2010 of the European Parliament and of the Council of 24 November 2010 establishing a European Supervisory Authority (European Securities and Markets Authority), amending Decision No 716/2009/EC and repealing Commission Decision 2009/77/EC (OJ L 331, 15.12.2010, p. 84, ELI: http://data.europa.eu/eli/reg/2010/1095/oj). 2/10 ELI: http://data.europa.eu/eli/reg_impl/2025/2179/ojEN OJ L, 30.12.2025 4. Where a requirement of Regulation (EU) 2023/2631 does not apply to the application for registration, applicants shall state that in the relevant table set out in the Annex to this Regulation and shall provide an explanation. 5. Applicants shall accompany their application for registration with a letter signed by a member of the applicants’ senior management, attesting that the submitted information is accurate and complete to the best of that member’s knowledge, as of the date of that submission. 6. Personal data relating to applicants for registration as an external reviewer shall be kept by external reviewers and ESMA for as long as it is necessary for the assessment of the initial registration and no longer than five years after that applicant has ceased to perform its function. Where ESMA has refused the registration of the applicant external reviewer or where the applicant withdraws its application, personal data relating to that applicant should be kept by ESMA no longer than five years after the refusal of the registration of the applicant or after the withdrawal of the application. Article 2 Entry into force This Regulation shall enter into force on the twentieth day following that of 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. Done at Brussels, 12 September 2025. For the Commission The President Ursula VON DER LEYEN ELI: http://data.europa.eu/eli/reg_impl/2025/2179/oj 3/10ANNEX I DOCUMENT REFERENCES Annex to this Regulation Unique reference Chapter or section or page of the document where the Title of the Specific requirement of Regulation (EU) 2023/2631 to which to which the information number of the information is provided or reason why the information is not document the information relates relates (II–VII) document provided 4/10 ELI: http://data.europa.eu/eli/reg_impl/2025/2179/oj EN OJ L, 30.12.2025ANNEX II GENERAL INFORMATION OF THE APPLICANT Full name of the applicant Address of registered office within the Union [Country, city, street address, postal code] Website Legal Entity Identifier (LEI) (where available) Contact person(s) Name Title Address [Country, city, street address, postal code] Email address Telephone number Legal form of the applicant ELI: http://data.europa.eu/eli/reg_impl/2025/2179/oj 5/10 OJ L, 30.12.2025 ENANNEX III OWNERSHIP STRUCTURE OF THE APPLICANT Percentage of the voting Owner Percentage of capital Nature of the holding rights [Please specify whether legal or natural person] [Direct or indirect] 6/10 ELI: http://data.europa.eu/eli/reg_impl/2025/2179/oj EN OJ L, 30.12.2025ANNEX IV MEMBERS OF SENIOR MANAGEMENT AND THE BOARD OF THE APPLICANT Submitted documents Member of Declaration of fitness and Proof of the absence of criminal Board senior propriety and conflicts of Name Date of birth Place of birth Role records referred to in Article 1(2), member manage­ interest referred to in CV point (a), of Commission ment Article 1(2), point (b), of Delegated Regulation Commission Delegated (EU) 2025/2180 Regulation (EU) 2025/2180 [Unique [Unique reference number] [Unique reference number] [City, [First name] [Last name] [Yes/No] [Yes/No] [DD/MM/YYYY] reference Country] number] ELI: http://data.europa.eu/eli/reg_impl/2025/2179/oj 7/10 OJ L, 30.12.2025 ENANNEX V ANALYTICAL RESOURCES OF THE APPLICANT (a) Information regarding analysts, employees and other persons that will be directly involved in assessment activities [Please select the appropriate column] Name Role Years in role Years in the industry CV Temporary Permanent [for instance, number of years working [Unique reference number of the in assessment activities similar to those document] tasks required of an external reviewer pursuant to Regulation (EU) 2023/2631] The information on the number of employees shall be provided on a full-time equivalent (FTE) basis calculated as the total hours worked divided by the maximum number of hours subject to compensation within a working year as defined by the relevant national law. (b) Information regarding the assessment activities Estimated duration of an external review [number of days] Expected number of assessments in the next 24 months [number] (c) Information on the evaluation of the applicant Reasons that the applicant considers the number of analysts, employees and other persons directly involved in assessment activities and their roles to be appropriate Reasons that the applicant considers the number and duration of external reviews to be appropriate 8/10 ELI: http://data.europa.eu/eli/reg_impl/2025/2179/oj EN OJ L, 30.12.2025ANNEX VI POLICIES AND PROCEDURES OF THE APPLICANT Unique reference number of the Point Topic document 1 Training and development plan for analysts, employees and other persons directly involved in assessment activities 2 Policies and procedures put in place to ensure: (a) the continuity and regularity in the performance of assessment activities; (b) the safeguarding of the confidentiality and security of records and documents on the services provided; (c) sound administrative and accounting procedures; (d) the adequacy of information processing systems implemented to meet the obligations of an external reviewer. 3 Policies and procedures outlining the internal control framework [In case of a large number of documents, the documents shall be grouped according to the relevant areas of the internal control framework.] 4 Policies and procedures to ensure the internal control framework complies with the criteria referred to in Article 5(2) of Delegated Regulation (EU) 2025/2180 5 Whistleblower policy ensuring that the anonymity of whistleblowers is safeguarded and reprisals are prohibited 6 Remuneration policy ensuring the independence of the employees subject to variable compensation arrangements 7 Procedures and methodologies implemented to issue reviews 8 Terms of reference of the governance bodies, including the board and, where established, its committees 9 Last meeting minutes of the board 10 Organisational chart, including the identification of reporting lines and job functions 11 Conflicts of interest policy 12 Inventory of actual or potential conflicts of interest and proposed mitigation measures 13 Information on how potential conflicts of interest situations, including transactions with related parties, employee personal account dealing, outside business activities and the acceptance of gifts and hospitality are reviewed and approved consistently 14 Documents and information related to any existing or planned outsourcing arrangements for activities of the applicant as an external reviewer covered by Regulation (EU) 2023/2631, including information on entities assuming outsourcing functions referred to in Article 7(2) of Delegated Regulation (EU) 2025/2180, and the evaluation of how the applicant will ensure compliance with Article 33(1) of that Regulation ELI: http://data.europa.eu/eli/reg_impl/2025/2179/oj 9/10 OJ L, 30.12.2025 ENANNEX VII OTHER ACTIVITIES OF THE APPLICANT Activity Description Offered through subsidiaries [Yes/No: if yes, please provide the name of [NACE code of the activity, where available] the entity] 10/10 ELI: http://data.europa.eu/eli/reg_impl/2025/2179/oj EN OJ L, 30.12.2025

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