What sustainability data your bank will ask for before lending

Your bank will ask for four blocks of information: energy consumption and scope 1 and 2 emissions, the economic activity being financed and how it maps to the EU taxonomy, the exposure of your assets to physical and transition risk, and reduction targets backed by a plan. It is not a matter of conviction: its own prudential rulebook requires it.

Why does the bank ask for sustainability data if I have no reporting obligation?

Because the obligation is theirs, not yours. The revision of the capital requirements directive, Directive (EU) 2024/1619, introduced Article 87a: institutions must identify, measure and manage environmental, social and governance risks, put in place specific plans for the financial risks arising from those factors over the short, medium and long term, and take the EU's 2050 climate neutrality objective as a reference. The same directive empowered the European Banking Authority to spell out how.

The European Banking Authority guidelines on the management of ESG risks develop that obligation, and this is where you come in. An institution has to gather and use enough information to assess the ESG risks it is exposed to through its counterparties, at client and asset level; from large corporate counterparties it has to collect current and expected scope 1, 2 and 3 emissions along with transition plans; and that assessment is part of ordinary first line of defence work, meaning client onboarding, credit application and credit review. That is why the conversation reaches companies with no reporting obligation of their own.

In Spain there is a second layer. Articles 32 and 33 of Law 7/2021 on climate change and energy transition require credit institutions, insurers and listed companies to publish an annual report on the financial impact of climate-related risks, and require credit institutions to publish decarbonisation targets for their lending and investment portfolios aligned with the Paris Agreement. Their portfolio targets are met with your data.

What exactly will they ask for?

Two practical warnings. First, the question about asset locations is not paperwork: it lets the bank cross your sites against flood, drought and wildfire risk maps, and it can affect how collateral is valued. Second, what the loan funds determines whether the exposure can count as taxonomy aligned, and that is decided against specific technical screening criteria, not a statement of intent. The general framework is covered in how the EU green taxonomy affects your business.

Why does the bank want you to report even when you do not have to?

Because of the green asset ratio. Article 8 of the Taxonomy Regulation requires financial institutions to disclose what share of their assets finances taxonomy-aligned activities, and that indicator is the GAR.

Here is the part that matters to a mid-sized company. Commission Delegated Regulation (EU) 2026/73 of 4 July 2025, amending Delegated Regulation (EU) 2021/2178, excludes from the calculation of financial institutions' KPIs, and therefore from the GAR, exposures to undertakings that are not required to include sustainability information in their management report. With one express exception: exposures to undertakings that voluntarily present their taxonomy KPIs using the regulation's own templates can be included. The regulation applies from 1 January 2026 and also cuts the number of required datapoints in the reporting templates substantially, for both non-financial and financial undertakings.

Translated: if you report voluntarily and in an aligned way, your exposure can add to the numerator of an indicator the bank publishes and its investors watch. That is a genuine negotiating point, not a gesture. The same logic applies to financed emissions: the PCAF standard for the financial industry, whose Part A is now in its third edition of 2025, scores the data quality of each exposure, and company-reported and verified emissions sit at the best end of that scale while estimates derived from revenue or assets sit at the worst. Well documented data from you improves the quality score of the bank's portfolio. It is the same pressure described in the analysis of the ECB, investors and sustainability data.

What format should you prepare the data in?

The European voluntary sustainability reporting standard, the one the Commission adopted on 3 July 2026 building on EFRAG's VSME. It is the shape everything is converging on, from large customers to lenders to public tenders, and it has a practical advantage: its basic module covers energy consumption, scope 1 and location-based scope 2 emissions and intensity over turnover, which is exactly the core of any bank questionnaire.

Build it once in that shape and you stop filling in a different form for every lender. Add the part specific to each transaction, the purpose of the loan and the environmental improvement it funds, and you have covered almost everything you will be asked without starting over each time.

What changes if the loan is sustainability-linked?

You move from supplying data for an assessment to contractually committing to an outcome. The Sustainability-Linked Loan Principles, updated on 26 March 2025, are built on five core components: selection of key performance indicators, calibration of sustainability performance targets, loan characteristics, reporting and verification.

Two requirements deserve attention before signing. The first is calibration: targets must be ambitious, going beyond business as usual and beyond what regulation already requires, which means you cannot use something the law already obliges you to do as your target. The second is verification: post-signing external review by a qualified reviewer is mandatory for each target and measurement period, and reporting must be at least annual. That is a recurring cost worth budgeting from the start, and a good reason to pick indicators your current data system can actually measure.

How far does the CSRD trickle-down effect reach now?

Directive (EU) 2026/470, published on 26 February 2026 and in force since 18 March 2026, narrows sustainability reporting to companies with more than 1,000 employees on average and more than 450 million euros in net turnover, with the first reporting year starting on or after 1 January 2027. Member States have until March 2027 to transpose it.

The relevant piece for a company seeking finance is the value chain cap: a company in scope cannot require a value chain company with fewer than 1,000 employees on average to provide more information than the voluntary standard covers, and that company has the right to refuse. On 3 July 2026 the European Commission adopted the delegated acts containing the revised ESRS, which cut mandatory datapoints by more than 60%, and the voluntary standard for smaller companies, built on EFRAG's VSME and endorsed through Recommendation (EU) 2025/1710.

Beware a common confusion: that cap governs what a CSRD-scope customer can demand of you, not what a bank can request as part of its credit risk analysis. A lender can still ask for whatever it needs to assess the transaction. What the voluntary standard does is set a shared language that saves you filling in ten different questionnaires. The new perimeter is set out in the analysis of the Omnibus package and ESG reporting in 2026 and in the guide to simplified ESRS standards for SMEs.

Checklist before the meeting with your bank

• Carbon footprint for the last closed financial year, with scope 1 and 2 calculated from invoices and the method documented.
• Total energy consumption in MWh and the renewable share evidenced by guarantees of origin.
• Emissions intensity over turnover, the metric that lets a lender benchmark you against your sector.
• Reduction plan with base year, quantified target, specific measures and the investment behind them.
• List of sites with exact addresses and the energy performance certificate for each building.
• Technical description of the project you want financed, with the environmental improvement quantified and the criterion behind it.
• Status of environmental permits and waste management, with no gaps.
• The assumptions log behind the calculation, so you can say where every figure comes from without improvising.

If your footprint is third-party verified or registered with MITECO, bring the evidence. Neither is mandatory for a private company, but both shorten the conversation about data reliability. The actual obligations are summarised in the guide to the carbon footprint registry and Royal Decree 214/2025, and how to structure a defensible plan is covered in the guide to carbon footprint reduction plans.

Frequently asked questions

Can a loan be refused because I have no sustainability data?

No rule requires a lender to refuse credit on that ground. What does happen is that, without data, the institution has to estimate your profile from sector averages, and a conservative estimate rarely helps your pricing or your tenor. Missing data does not block the transaction, it makes it more expensive.

Do I need a third-party verified footprint?

For a working capital line, usually not. For a sustainability-linked loan there is mandatory post-signing verification of target performance under the market principles updated in 2025. For labelled green project finance, it depends on the framework the lender uses.

Is scope 1 and 2 enough, or will they ask for scope 3?

Well calculated scope 1 and 2 covers most SME questionnaires. Scope 3 is mainly requested from large corporate counterparties, which is what the European Banking Authority guidelines set out, and in sectors where almost all the emissions sit in the value chain. If you have it, provide it even if estimated, stating the method.

Can the same data pack serve several lenders?

Largely yes, and increasingly so, because the content is converging on the European voluntary sustainability reporting standard. Build one dossier in that shape and adapt only the part specific to each transaction.

What do I get out of providing this data?

Three concrete things: being inside the bank's green asset ratio calculation instead of excluded from it, improving the data quality score attached to your financed emissions, and negotiating terms on facts rather than assumptions. The same dossier usually works for public tenders and large customers too.

The information a bank asks for is, almost point by point, the information you already need for your own obligations and for your customers. Building it once and keeping it current is what turns the exercise into leverage. That is what Manglai's carbon footprint software and its approach for CFOs are for, and if you want the wider picture, start with what sustainable finance means for a business.