Green Bond Standard (EU GBS)
The European Green Bond Standard (EU GBS – Regulation (EU) 2023/2631) is a voluntary standard developed by the European Commission to foster the growth of a transparent and resilient green bond market within the EU. The EU GBS Regulation was published in the Official Journal of the EU on 30 November 2023, and following its entry into force on 20 December 2023, its provisions apply from 21 December 2024. The Regulation establishes a set of standards that bond issuers – companies and public authorities – can choose to follow for issuing bonds labelled as EU Green Bonds (EU GB).
An EU Green Bond is defined as any type of bond or capital market debt instrument whose proceeds will be exclusively used to finance or refinance in part or in full new and/or existing green projects meeting environmental objectives as per the EU Taxonomy. Visit the EU Taxonomy section for further information.
The EU GBS establishes four key requirements to be fulfilled:
- Taxonomy-alignment: all the funds an EU GB raises must be fully allocated to projects aligned with the EU Taxonomy. For those sectors not yet covered by the EU taxonomy and certain very specific activities, a flexibility pocket of 15% is foreseen;
- Transparency: full transparency on how the bond proceeds are allocated through detailed reporting requirements including, i) pre-issuance of a green bond factsheet, ii) post-issuance of an allocation, and iii) impact report, as well as iv) pre-issuance and v) post-issuance performance of external reviews;
- External review: an external registered reviewer must check all EU GBs to ensure compliance with the regulation and taxonomy alignment of the funded projects. Please note, non-EU external reviewers can also provide services under the EU GBS through the third-country regime, which offers routes via equivalence, endorsement by an EU-registered reviewer or recognition;
- Supervision by the European Securities and Markets Authority (ESMA) of reviewers: Since 21 June 2026, all entities providing external review services in respect of EUGBs must be formally registered with, and supervised by ESMA. This will ensure the quality of their services and the reliability of their reviews to protect investors and ensure market integrity. Please note, registration carries a fee of EUR 40,000, with annual supervisory fees thereafter, as set out in Commission Delegated Regulation (EU) 2025/755.
Please note, issuers of other green bonds and sustainability linked bonds can use optional disclosure templates. When they do, national competent authorities supervise issuers of bonds marketed as environmentally sustainable and of sustainability-linked bonds who decide to use the post-issuance disclosure templates.
The EU GBS aims to help scale up and raise the environmental ambitions of the green bond market. It also aims to foster environmentally sustainable investments, while increasing investor protection.
In this regard, it also has the objective of helping investors find and finance environmentally sustainable investments while relying on a trustworthy standard. Once in place, investors can invest in a bond segment that ensures a high degree of market integrity, transparency, and comparability as this segment provides a common definition of environmentally sustainable or “green”, aligned with the EU Taxonomy. Additionally, assurance and credibility are ensured by requiring issuers to prepare pre-issuance and post-issuance reports which are subject to review by an external reviewer and the possibility of obtaining an external review of post-allocation impact reports.
The EU GBS has been developed in response to the growing demand for green bonds financing assets needed for the low-carbon transition.
The EU GBS applies to all types of bond issuers, including public and private issuers, and provides them with a voluntary standard. These bond issuers can be financial or non-financial companies located within and outside the EU.
In addition, national competent authorities supervise issuers and securitisation originators of European Green Bonds, except where these are issued by an EU sovereign or guaranteed by certain EU sovereigns.
Financial market participants (FMPs) investing in bonds that comply with the EU GBS will benefit from a standardised set of information the issuers must provide.
Considering the link with the EU Taxonomy, the GBS will enable financial market participants to acquire reliable information on the taxonomy alignment of a specific bond, making it a financial instrument designed to increase the overall taxonomy alignment of other financial products, such as investment funds.
In addition, issuers planning to issue a European Green Bond should consult ESMA’s register to select a registered external reviewer for their pre-issuance, post-issuance and, where applicable, impact report reviews. When the register opened on 22 June 2026, five firms were registered, including entities of Moody’s, Sustainable Fitch and S&P Global Ratings. ESMA updates the register regularly as new applications are approved, so issuers should check the current list rather than relying on their historical provider.
The EU Green Bond Standard (EUGBS) forms part of the EU’s broader sustainable finance framework and supports the objectives of the European Green Deal.
The EUGBS is closely linked to the EU Taxonomy, as Article 4 of Regulation (EU) 2023/2631 requires proceeds to be allocated to specified uses aligned with the Taxonomy Regulation (EU) 2020/852. Limited flexibility is permitted under Article 5, which allows up to 15% of proceeds to be allocated to certain activities that meet the Taxonomy requirements other than the technical screening criteria, where no such criteria were in force at issuance or where the activites are carried out in the contextof international support.
Changes to the EU Taxonomy can therefore directly affect the allocation of proceeds under the EuGBS. Commission Delegated Regulation (EU) 2026/73, published in the Official Journal on 8 January 2026, simplified Taxonomy disclosures and certain technical screening criteria, including criteria relating to the do no significant harm criteria. A broader review of the technical screening criteria under the Climate and Environmental Delegated Acts was open for public feedback until 14 April 2026.
To provide issuers with legal certainty, Article 8 of the EUGBS Regulation establishes a grandfathering mechanism. Issuers initially allocate proceeds in accordance with the technical screening criteria applicable at the time of bond issuance. Where those criteria are subsequently amended, unallocated proceeds and certain proceeds covered by CapEx plans must comply with the amended criteria no later than seven years after their application date.
Visit the EU Taxonomy section for further information.
As an EU Regulation, the EU GBS applies directly in Luxembourg and has not required transposition into national law, so there are no Luxembourg-specific rules for issuers. Luxembourg has, however, adopted an implementing law that deals with the points the Regulation leaves to Member States.
The Law of 6 February 2025 designates the CSSF as the competent authority responsible for ensuring the application of Regulation (EU) 2023/2631 and gives it sanctioning powers. These include the power to prohibit an issuer from issuing European green bonds for up to one year for repeated and serious breaches. The CSSF supervises issuers of European Green Bonds for compliance with their transparency and information obligations, as well as issuers that use the optional post-issuance disclosure templates. It has also set up a notification procedure, which requires issuers under its supervision to inform it each time they publish one of the required EUGB documents. External reviewers are registered with and supervised by ESMA, not the CSSF. Further information is available on the CSSF’s dedicated European Green Bonds page.
- 05 October 2023: The EU GBS has been adopted by the European Parliament;
- 23 October 2023: The text has been formally adopted by the Council;
- 30 November 2023: Publication of the Regulation (EU) 2023/2631 (EU GBS) in the Official Journal of the European Union;
- 20 December 2023: Entry into force of the EU GBS Regulation;
- 21 December 2024: Application date of the EU GBS Regulation.
- 21 June 2026: Transitional regime for external reviewer ends
- 22 June 2026: ESMA published the register of firms authorised to act as external reviewers of European Green Bonds
- 06 March 2019: The Technical Expert Group (TEG) published its “Interim Report on EU Green Bond Standard”;
- 18 June 2019: The TEG published its final “Report on EU Green Bond Standard”;
- 09 March 2020: The TEG published its usability guide for the standard, including an updated proposal for a green bond standard;
- 12 June 2020: The Commission launched a targeted consultation on establishing a European green bond standard, closing on 2 October 2020;
- 06 July 2021: The European Commission presented its proposal for a Regulation on a European Green Bond Standard;
- 28 February 2023: The co-legislators reached a provisional agreement after inter-institutional negotiations;
- 05 October 2023: The European Parliament adopted the Regulation in plenary;
- 23 October 2023: The Council formally adopted the Regulation;
- 30 November 2023: Regulation (EU) 2023/2631 was published in the Official Journal of the EU;
- 20 December 2023: The Regulation entered into force;
- 21 December 2024: The Regulation began to apply. An 18-month transitional regime for external reviewers started, under which reviewers could operate on the basis of notification to ESMA, with “best efforts” compliance with the substantive requirements;
- 06 February 2025: A Luxembourg law implementing the Regulation was adopted. It designates the CSSF as the competent authority responsible for ensuring its application;
- 14 February 2025: ESMA published its final report on the first set of technical standards for the external reviewer regime and submitted them to the Commission;
- 07 April 2025: ESMA published a consultation paper on the remaining technical standards for external reviewers, which closed on 30 May 2025;
- 16 April 2025: The Commission adopted three Delegated Regulations: (EU) 2025/753 on templates for voluntary post-issuance disclosures, (EU) 2025/754 on procedures for ESMA fines and periodic penalty payments, and (EU) 2025/755 on fees charged by ESMA to external reviewers;
- 25 July 2025: The three Delegated Regulations were published in the Official Journal, together with a Commission Communication setting non-binding guidelines for voluntary pre-issuance disclosure templates. The Delegated Regulations entered into force on 14 August 2025;
- 12 September 2025: The Commission adopted Implementing Regulation (EU) 2025/2179 on the forms and procedures for applying for registration as an external reviewer and Delegated Regulation (EU) 2025/2180 on registration conditions, sound and prudent management, staff knowledge and training, and outsourcing;
- 15 October 2025: ESMA published its final report on the remaining regulatory and implementing technical standards and submitted them to the Commission;
- 05 November 2025: The Commission published FAQs on the interpretation and implementation of certain provisions of the standard;
- 12 March 2026: The Commission adopted Delegated Regulation (EU) 2026/544 on external reviewers’ systems, resources and procedures, compliance function, assessment methodologies, and applications for recognition of third-country external reviewers;
- 16 March 2026: The Commission published a corrigendum to the FAQs, including updated guidance on allocating proceeds to capital expenditure incurred before issuance;
- 17 June 2026: Implementing Regulation (EU) 2026/543 (notification of material changes to registration information) and Delegated Regulation (EU) 2026/544 were published in the Official Journal, entering into force on 7 July 2026;
- 21 June 2026: The transitional regime ended. All entities providing external review services for European Green Bonds must now be registered with, and supervised by, ESMA;
- 22 June 2026: ESMA published the register of firms authorised to act as external reviewers of European Green Bonds. Reviewers listed in the transitional register had to cease their activities, and ESMA created a separate register for previously issued European Green Bonds.
Where we stand now: The regime is now fully operational. Market uptake is growing but still modest. By March 2026 there had been more than 30 issuances with a total volume of about EUR 30 billion, and in 2025 European green bonds made up around 7% of all green bond issuances in Europe. See further information here: https://finance.ec.europa.eu/news/shaping-sustainable-future-key-updates-eu-green-bonds-2026-03-19_en
Currently, there is no consultation open or pending
Core legislation
- Regulation (EU) 2023/2631 on European Green Bonds and optional disclosures for bonds marketed as environmentally sustainable and for sustainability-linked bonds
- European Green Bonds: Council adopts new regulation to promote sustainable finance (press release, 24 October 2023)
Delegated and implementing acts
- Commission Delegated Regulation (EU) 2025/753 – templates for voluntary periodic post-issuance disclosures
- Commission Delegated Regulation (EU) 2025/754 – rules of procedure for ESMA fines and periodic penalty payments on external reviewers
- Commission Delegated Regulation (EU) 2025/755 – fees charged by ESMA to external reviewers
- Commission Delegated Regulation (EU) 2025/2180 – conditions for registration of external reviewers, sound and prudent management, staff knowledge and outsourcing
- Commission Delegated Regulation (EU) 2026/544 – external reviewers’ systems, procedures, methodologies and recognition of third-country reviewers
- Commission Implementing Regulation (EU) 2025/2179 – forms and procedures for applying for registration as an external reviewer
- Commission Implementing Regulation (EU) 2026/543 – notification of material changes to registration information
- European Commission – overview of implementing and delegated acts under the European Green Bond Standard
Commission guidance
- Commission FAQs on the interpretation and implementation of certain provisions of the European Green Bond Standard (C/2025/5885)
- Corrigendum to the Commission FAQs (March 2026)
- Commission Communication – guidelines and templates for voluntary pre-issuance disclosures (C/2025/2277)
- European Commission – The European green bond standard: Supporting the transition
- European Commission – Shaping a sustainable future: key updates for EU green bonds (19 March 2026)
ESMA and external reviewers
- ESMA – External Reviewers of European Green Bonds (including the register)
- ESMA publishes the register of external reviewers under the EuGB Regulation (22 June 2026)
- ESMA Final Report on Technical Standards under the EuGB Regulation (February 2025)
- ESMA Final Report on Technical Standards under the EuGB Regulation (October 2025)
Luxembourg
- CSSF – European green bonds and other sustainable bonds
- Law of 6 February 2025 implementing Regulation (EU) 2023/2631 (Legilux)
Background: Technical Expert Group reports
- Final Report on EU Green Bond Standard (June 2019)
- EU Green Bond Standard Usability Guide (March 2020)
