Fees for registration, recognition and supervision of external verifiers of European green bonds approved

Environmentally sustainable bonds are one of the main instruments for financing investment related to environmentally sustainable technologies, energy and resource efficiency, as well as environmentally sustainable transport infrastructure and research infrastructure.

Given its importance and the absence of common standards, Regulation (EU) 2023/2631 of the  European Parliament and of the Council of 22 November 2023 on European green bonds and optional disclosure for bonds marketed as environmentally sustainable bonds and for sustainability-linked bonds was approved. Said regulation, in what is of interest here:

1. lays down uniform requirements for bond issuers wishing to use the designation 'European Green Bond' or 'EuGB' for their bonds made available to investors in the Union;
2. establishes a system to register and supervise external verifiers of European green bonds, and
3. empowers the European Securities and Markets Authority (ESMA) to charge external verifiers fees related to their registration, recognition and supervision. Those fees must meet two requirements: first, they must cover the administrative costs incurred by ESMA in its activities in relation to the registration and supervision of all external verifiers; In addition, the fees shall be proportionate to the turnover of the external verifier concerned.

Pursuant to the latter provision, Commission Delegated Regulation (EU) 2025/755 of 16 April 2025 supplementing Regulation (EU) 2023/2631 of the European Parliament and of the Council was published in the OJEU on 25 July 2025, specifying the type of fees to be charged by ESMA to external verifiers of European green bonds, the concepts for which they will be due, their amount and the payment methods.

Two categories of fees are established:

1. Registration, acknowledgement and authorisation fees: they shall be payable at the time the external verifier submits the application for registration, acknowledgement or authorisation and shall be paid in full within thirty days from the date on which ESMA's invoice is issued. The amount to be paid will be as follows:
   • Persons or entities applying for registration as an external verifier of European green bonds in accordance with Article 23 of Regulation (EU) 2023/2631: €40,000.
   • Third-country third-party verifiers applying for registration as third-party verifiers of European green bonds in accordance with Article 39 of Regulation (EU) 2023/2631: €10,000.
   • Third-country third-party verifiers applying for recognition in accordance with Article 42(1) of Regulation (EU) 2023/2631: €40,000.
   • External verifiers of European green bonds applying, after registration, for authorisation to be external verifiers responsible for validation in accordance with Article 43(1) of Regulation (EU) 2023/2631: €20,000.
2. Annual supervisory fees: they shall be payable at the beginning of each calendar year and shall be paid in full to ESMA in the first three months of that year. ESMA shall submit to each external verifier an invoice specifying the supervisory fee due no later than 30 days before the final date of payment. The amount to be paid will be as follows:
   • External verifiers whose annual turnover generated at group level is less than €5,000,000: exemption until the end of the third full calendar year following registration or recognition, as applicable.
   • Other external verifiers: an amount calculated in accordance with the methodology described in the regulation of not less than €30,000 and not more than 3% of their applicable turnover.

The regulation will enter into force twenty days after its publication in the Official Journal of the European Union (25 July 2025) and will be binding in its entirety and directly applicable in all Member States.