MEMBERS - Transparency for Whom? Europe’s New Rules for Credit Rating Agencies

In November 2026 the European Commission adopted rules requiring credit rating agencies to explain whether and why environmental, social and governance (ESG) considerations bear on their assessments of creditworthiness, and to identify ESG factors that are key elements of individual ratings. The rules raise a question older than the ESG agenda. When European law requires credit rating agencies to explain themselves, to whom is the explanation addressed, what does it place in public view, and what kind of scrutiny does it make possible? Some provisions address investors, issuers, and other users who read published methodologies and press releases. Others address the European Securities and Markets Authority (ESMA), which can examine the records, committee papers, and validation work behind a rating. The framework relies on both audiences, yet its texts say little about how the two forms of scrutiny relate.