EU Green Bond Regulation Requires External Reviewer Registration by June 21, 2026

• External reviewers are required for issuers of European Green Bonds to ensure compliance with Taxonomy requirements.
• Firms must register with ESMA by June 21, 2026, and pay a registration fee of EUR 40,000.
• A third-country regime allows non-EU external reviewers to operate under an equivalence decision or with a legal representative in the EU.
• The endorsement regime is available for EU-based external reviewers who wish to endorse services provided by third-country reviewers.

Firms wishing to provide external reviewer services after June 21, 2026, must submit an application to ESMA, which will acknowledge receipt within one working day.

The European Union's (EU) Green Bond Regulation has introduced a new requirement for issuers of European Green Bonds to use an external reviewer. These reviewers provide an independent opinion on whether the issuer complies with the Taxonomy requirements of the EU Green Bonds Regulation. The European Securities and Markets Authority (ESMA) is responsible for registering and supervising these external reviewers, who must be registered by June 21, 2026. Firms wishing to provide external reviewer services after this date must submit an application to ESMA, which will acknowledge receipt within one working day. A registration fee of EUR 40,000 applies, as per Article 1(1) of the Commission Delegated Regulation (EU) 2025/755 of April 16, 2025.

The EU Green Bond Regulation was published in the Official Journal of the European Union on November 30, 2023, and entered into force on December 21, 2023. The Regulation applies since December 21, 2024. It includes a third-country regime for non-EU external reviewers of EU Green Bonds, which allows them to operate under an equivalence decision adopted by the European Commission. In the absence of such a decision, these reviewers must have a legal representative established in the EU and comply with the Regulation's requirements. The endorsement regime is also available for EU-based external reviewers who wish to endorse services provided by third-country reviewers.

Lawyers advising on EU Green Bond issuances should ensure their clients are aware of the registration requirements and timeline for external reviewers. This includes submitting applications by June 21, 2026, and complying with the Regulation's stringent requirements. The registration process involves submitting an application to ESMA, which will acknowledge receipt within one working day. A registration fee of EUR 40,000 applies, as per Article 1(1) of the Commission Delegated Regulation (EU) 2025/755 of April 16, 2025. Firms must also comply with the requirements of the EuGB Regulation and demonstrate that their services meet or exceed the standards set by the EU Green Bond Regulation.

Lawyers advising on EU Green Bond issuances should ensure their clients are aware of the registration requirements and timeline for external reviewers, including the need to submit applications by June 21, 2026, and comply with the Regulation's stringent requirements.

Source: Original reporting via EU Green Bond Regulation implementation timeline