Regulation on ESG rating providers

Regulation (EU) 2024/3005 on the transparency and integrity of Environmental, Social and Governance (ESG) rating activities (ESG Rating Regulation)

Regulating the ESG rating market by regulating ESG rating providers operating in the EU

Level 1

Entry into force

New EU Regulation on ESG ratings published (18 December 2024)

1 January 2025

2 October 2025

Level 2

Application for authorisation to operate in the EU

ESMA to develop draft regulatory technical standards (RTS) to specify further the information listed in Annex I (Information to be provided in the application for authorisation).

Update 2 May 2025: ESMA published a consultation paper on regulatory technical standards to specify the information to be contained in an application for authorisation or recognition to operate in the EU as an ESG rating provider. ESMA will consider feedback received and expects to publish a final report and submit the draft RTS to the EU Commission for adoption by end of October 2025.

No specific timeline

Level 2

Equivalence regime

EU Commission may adopt an equivalence decision by means of an implementing act stating that the legal framework and supervisory practice of a third country ensure that:

  • ESG rating providers authorised or registered in that third country comply with binding requirements which are equivalent to the requirements of the Regulation;
  • Compliance with the binding requirements is subject to effective supervision and enforcement on an ongoing basis in that third country.

EU Commission may adopt a delegated act to specify these conditions.

2 October 2025

Level 2

Recognition of ESG rating providers established outside the EU

ESMA to develop draft regulatory technical standards to determine the form and content of the application for recognition referred to in Article 12(2) (Recognition of ESG rating providers established outside the EU), and, in particular, the presentation of the information required in Article 12(4).

Update 2 May 2025: ESMA published a consultation paper on regulatory technical standards to specify the information to be contained in an application for authorisation or recognition to operate in the EU as an ESG rating provider. ESMA will consider feedback received and expects to publish a final report and submit the draft RTS to the EU Commission for adoption by end of October 2025.

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No specific timeline

Level 2

Register of ESG rating providers and accessibility of information on the European single access point

ESMA to develop draft implementing technical standards to specify:

  • any other metadata to accompany the information (i.e. the information referred to in Article 14(1) (Register of ESG rating providers and accessibility of information on the European single access point));
  • the structuring of data within the information;
  • the information for which a machine-readable format is required, and which machine-readable format is to be used.

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No specific timeline

Level 3

Register of ESG rating providers and accessibility of information on the European single access point

Where necessary, ESMA to adopt guidelines for entities to ensure that the metadata submitted in accordance with Article 14(8)(a), (i.e. any other metadata accompanying the information referred to in Article 14(1) (Register of ESG rating providers and accessibility of information on the European single access point)), are correct.

2 October 2025

Level 2

Separation of business and activities

ESMA to develop draft regulatory technical standards to specify the details of the measures and safeguards to be implemented pursuant to Article 16(2), (3) and (4) (Separation of business and activities).

Update 2 May 2025: ESMA published a consultation paper on regulatory technical standards specifying the details of the measures and safeguards to be implemented by ESG rating providers in relation to the separation of business and activities. ESMA will consider feedback received and expects to publish a final report and submit the draft RTS to the EU Commission for adoption by end of October 2025.

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2 October 2025

Level 2

Disclosure to the public of the methodologies, models and key rating assumptions used in ESG rating activities

ESMA to develop draft regulatory technical standards to specify further the elements to be disclosed in accordance with Article 23(1), first subparagraph (Disclosure to the public of the methodologies, models and key rating assumptions used in ESG rating activities). Those elements must not include any additional disclosure requirements other than those listed in Annex III (Disclosure requirements), point 1.

ESMA may develop draft implementing technical standards to specify the data standards, formats and templates that ESG rating providers are to use to present the information referred to in Article 23(1).

Update 2 May 2025: ESMA published a consultation paper on regulatory technical standards with regard to the elements to be disclosed to the public and to users of ESG ratings, rated items and issuers of rated items. ESMA will consider feedback received and expects to publish a final report and submit the draft RTS to the EU Commission for adoption by end of October 2025.

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2 October 2025

Level 2

Disclosures to users of ESG ratings, rated items and issuers of rated items

ESMA to develop draft regulatory technical standards to specify further the elements that are to be disclosed in accordance with Article 24(1) (Disclosures to users of ESG ratings, rated items and issuers of rated items). Those elements must not include any additional disclosure requirements other than those listed in Annex III (Disclosure requirements), point 2.

ESMA may develop draft implementing technical standards to specify the data standards, formats and templates that ESG rating providers are to use to present information referred to in Article 24(1).

Update 2 May 2025: ESMA published a consultation paper on regulatory technical standards with regard to the elements to be disclosed to the public and to users of ESG ratings, rated items and issuers of rated items. ESMA will consider feedback received and expects to publish a final report and submit the draft RTS to the EU Commission for adoption by end of October 2025.

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2 October 2025

Level 3

Supervision by ESMA – general principles

ESMA, in cooperation with EBA and EIOPA, to issue and update guidelines on the application of the endorsement regime referred to in Article 11 (Endorsement of ESG ratings provided by ESG rating providers established outside the EU) of the Regulation.

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No specific timeline

Level 2

Supervision by ESMA – procedural rules for taking supervisory measures and imposing fines

EU Commission to adopt delegated acts to supplement the Regulation by adopting further rules of procedure for the exercise of ESMA’s power to impose fines or periodic penalty payments, including provisions on rights of defence, temporal provisions and the collection of fines or periodic penalty payments, and by adopting detailed rules on the limitation periods for the imposition and enforcement of fines and periodic penalty payments.

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Level 1

Entry into application

2July 2026

2 January 2026

Level 2

Supervisory fees

EU Commission to adopt delegated acts to supplement the Regulation by specifying the type of fees, the matters for which fees are due, the amount of the fees and the respective justification, the manner in which they are to be paid and, where applicable, the way in which ESMA is to reimburse the competent authorities in respect of any costs that they might incur when carrying out tasks pursuant to the Regulation, in particular as a result of any delegation of tasks as referred to in Article 43 (Delegation of tasks by ESMA to the competent authorities).

Level 1

Transitional provisions – existing ESG rating providers

ESG rating providers which were operating in the EU at the date of entry into force of the Regulation (i.e. 1 January 2025) must notify ESMA if they wish to continue operating in the EU and apply for authorisation or recognition in accordance with Title II (Provision of ESG ratings in the EU).

2 August 2026

Level 1

Transitional provisions – small ESG rating providers

Small ESG rating providers within the meaning of Article 5(1) (Temporary regime for small ESG rating providers), which were operating in the EU at the date of entry into force of the Regulation (i.e. 1 January 2025), must notify ESMA in accordance with Article 5 if they wish to continue operating in the EU.

2 November 2026

2 January 2029

Milestone

Review

EU Commission to evaluate the application of the Regulation and report on the main findings of the evaluation to the EU Parliament and the Council of the EU. The report must in particular assess the following:

  • the impact of the Regulation on the transition to a sustainable economy, on the gap of investments needed to meet the EU climate targets as set out in Regulation (EU) 2021/1119, and on redirecting private capital flows towards sustainable investments;
  • the impact of the Regulation on the market structure, including the evolution of the number and diversity of ESG rating providers;
  • whether the scope of the Regulation is appropriate to achieve its objectives in accordance with Article 1 (Subject matter), including whether providers of data products on environmental, social and human rights, and governance factors should be included in the scope of the Regulation;
  • the adequacy of the requirements for ESG rating providers established outside the EU to operate in the EU;
  • the functioning of the market of ESG rating providers in the EU, including potential conflicts of interest, and its supervision by ESMA;
  • whether the Regulation, including the non-interference principle referred to in Article 28 (Non-interference with the content of ESG ratings or methodologies), has contributed to improving the quality and reliability of ESG ratings and reduced the use of misleading ESG ratings.