ESMA · ESMA_QA_2737 Answer Published

Group-affiliated small ESG rating providers

Regulation
ESGR - Regulation (EU) 2024/3005
Topic
Temporary regime for small providers
Submitted
2025-12-18
Answered
2025-12-18

Question

Is a small ESG rating provider that is part of a medium-sized or large group eligible for the temporary regime under Article 5 of Regulation (EU) 2024/3005 when it is operating independently of the group’s resources and consolidated capacity?

Answer

No. Particular attention must be paid to Recital 48, according to which ESMA should ensure that risks of circumvention of the Regulation are avoided, “particularly by preventing small undertakings within medium-sized or large groups according to the criteria laid down in Directive 2013/34/EU from benefitting from the temporary regime”. The temporary regime was introduced to facilitate the market entry of smaller ESG rating providers by allowing them to benefit from more proportionate requirements for a three-year period.

This Q&A is published by European Securities and Markets Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

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