DNB Supervision under the European Green Bond Regulation

Factsheet

As of December 21, 2024, the European Green Bond Regulation 2023/2631 (EuGB Regulation) came into effect. The EuGB Regulation includes among other things requirements for institutions who wish to use the designation ‘European Green Bond’ or ‘EuGB’ for their securitisation bonds. The regulation aims to foster consistency and comparability in the green bond market and reduces the risk of greenwashing. The regulation can be found here.

Published: 27 January 2025

Requirements for the use of the designation European Green Bonds

The EuGB Regulation applies to bonds and securitisation bonds that want to be designated as a European Green Bond. The general requirements regarding the use of proceeds, transparency and external review are described in Chapters 1 and 2 of the EuGB Regulation; Chapter 3 describes the additional disclosure requirements in the case of securitisation bonds. This OBS Factsheet is only applicable to securitisation bonds that want to be designated as a ‘EuGB’, and that fall under the supervision of DNB.

Division of tasks between DNB and AFM in the supervision of EuGB-designated securitisation bonds

The supervision of European Green Bonds is set out in the EuGB Regulation. With respect to securitisation bonds, DNB and AFM have been designated as the competent authorities to supervise compliance with the obligations under Title II, Chapter 2, and Articles 18 and 19 of the EuGB Regulation. DNB is the competent authority to supervise the compliance of originators (as defined in Art. 2(3) of the Securitisation Regulation (SR)) with their obligations. AFM is the competent authority with respect to SSPEs.

Supervision DNB

Institutions should ensure that the securitisation bonds they initiate (or issue) and that they wish to designate as EuGB, meet the requirements imposed under the EuGB Regulation. DNB supervises compliance with these requirements.

DNB establishes transaction-oriented supervision for EuGB-securitisation bonds, assessing compliance with the requirements at different times: first at issuance and subsequently after the publication of any other required document.

DNB can on a continuous and random basis impose questions with regard to compliance to the EuGB-requirements. Note that there will be no formal prior or retrospective approval by DNB.

The assessment of whether a securitisation bond meets the requirements of the EuGB Regulation is independent from the assessment on whether a securitisation bond meets the SR-requirements. These are subject to separate processes, see DNB Supervision under the Securitisation Regulation.

Expectations DNB

DNB expects institutions using the EuGB designation for their securitisation bonds to notify DNB with undue delay of any publication of relevant documents. In practise, this means the following:

  • At issuance of the EuGB securitisation bond: institutions should notify the publication of the factsheet, the pre-issuance review and the approved prospectus to DNB and send a link to the published documents or if preferred the documents themselves to DNB. This can be done by email to: STS@dnb.nl
  • Upon appearance of any other required document: institutions should notify the publication of allocation reports, post-issuance reviews, impact report(s), and if applicable the CapEx plan and the assessment of the impact report (optional) to DNB and send a link to the published documents or if preferred the documents themselves to DNB. This can be done via the same email address: STS@dnb.nl.

The publication of these documents must also be notified to AFM. This can be done by sending an email to service.prospectus@afm.nl. For information about notifying AFM and their additional expectations, we refer to the AFM website: European green bonds.

The publication of these documents must also be notified to ESMA. For more information on this, see the website of ESMA.

Contact

Originators of securitisation bonds can contact STS@dnb.nl if they have any questions regarding DNB’s supervision under the EuGB Regulation.

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