ESMA publishes register of EuGB external reviewers
Only firms on ESMA's EuGB register may provide European Green Bond reviews; transitional-only firms must cease on 22 June 2026
Change
On 22 June 2026, the European Securities and Markets Authority (ESMA) brought registered external reviewers for European Green Bonds under its supervision and ended the Articles 69/70 transitional regime, requiring firms listed only in the transitional register to cease external review activities.
Why it matters
ESMA supervision makes registration and full compliance with EuGB rules a precondition for performing EuGB reviews, including requirements for senior-management accountability, analytical capability, robust methodologies, internal controls and conflicts-of-interest frameworks. Issuers must select reviewers from ESMA’s register for pre-issuance, post-issuance and, where applicable, impact-report reviews, narrowing the pool of eligible reviewers.
Implications
- — External reviewer firms providing European Green Bond external reviews must register with ESMA and implement clear senior-management accountability, robust and transparent methodologies, effective internal controls and a comprehensive conflicts-of-interest framework — firms not registered or not meeting these requirements must cease EuGB external-review activities from 22 June 2026.
- — Issuer ESG and capital-markets teams planning European Green Bond issuance must select an external reviewer listed on ESMA's register to perform pre-issuance, post-issuance and, where applicable, impact-report reviews — using an unregistered reviewer leaves the issuer without an ESMA-registered reviewer for EuGB disclosure.
Who is affected
- — External reviewer firms providing European Green Bond external reviews
- — Issuer ESG and capital-markets teams planning European Green Bond issuance
What to watch
- — 22 June 2026: registered external reviewers become subject to ESMA supervision and firms in the EuGB transitional register must cease external review activities.