Taxonomy Disclosures Delegated Act – ESAs to provide technical advice

By a letter electronically signed on 3 March, dated 4 March and published on 5 March 2026, the European Commission (Commission) has sent a call for technical advice (CTA) to the European Supervisory Authorities (ESAs) to complete the review and simplification of taxonomy reporting under the Disclosures Delegated Act, a Level 2 measure made under the Taxonomy Regulation.

The Commission is seeking advice primarily on the following Key Performance Indicators (KPIs) provided in the Disclosures Delegated Act:

• the operational expenditure (OpEx) KPI of non-financial firms
• Commissions and Fees KPI and Trading Book KPI of credit institutions and
• the underwriting KPI of insurance/re-insurance undertakings.

The ESAs should also consider whether other targeted technical amendments are needed to the Disclosure Delegated Act in order to simplify and enhance the usability of taxonomy reporting.

Context of the CTA

The CTA notes that the Omnibus Delegated Act published in January 2026 has already simplified Taxonomy reporting, reduced the number of datapoints to be reported, postponed reporting of certain KPIs by banks and streamlined the ‘do no significant harm’ (DSNH) criteria on the use of chemicals.

The current review is to concentrate on measures that were not addressed in the Omnibus Delegated Act and the ESAs’ work will take place alongside ongoing work to amend the SFDR.

The CTA also notes that the Commission’s more general review of technical screening criteria (TSC) under the Taxonomy Regulation is ongoing – this is due to be finalised in Q3 2026.

Scope of the CTA

Non-financial undertakings

Although the turnover and capital expenditure (CapEx) Key Performance Indicators (KPIs) covering companies’ revenues and longer-term investments are considered to be well understood by stakeholders and easy to apply, the operating expenditure (OpEx) KPI, which mainly focuses on the day-to-day maintenance costs of corporates is felt to be of limited use and overly burdensome since it does not consider the different importance of various operating expenditures in different economic sectors.

Financial undertakings

The Omnibus Delegated Act has addressed the need to simplify the Green Asset Ratio (GAR) of banks and the investment KPIs (GIR) of other financial undertakings by generally excluding exposures to SMEs, for whom the Taxonomy criteria are too ambitious, and who need a more proportionate framework for sustainable/transition finance.

To complete the review of the Disclosures Delegated Act, there needs to be a focus on simplifying the remaining KPIs of financial undertakings which are burdensome and less relevant than the GAR/GIR.

In drawing up the technical advice requested, the ESAs are expected to “consult relevant stakeholders on appropriate technical measures proposed, assess stakeholders’ data and analyse the impacts that their technical advice might have on undertakings, including in terms of costs and benefits”.

Scope of each ESA’s work

ESMA is invited to provide technical input on

• broadening the scope of the OpEx KPI denominator
  The CTA suggests that a wider list of OpEx categories could include items relevant for financing the environmental transition (such as OpEx related to R&D, operating leasing, low-carbon materials and green energy, purchasing low-carbon intermediate products e.g. inputs such as green steel, iron).
• reference to existing accounting standards for OpEx KPI
  Where possible, the identified OpEx categories should reference international accounting standards, to facilitate the identification of the OpEx covered by the reporting. The CTA states that the final advice is not expected to address the identification of OpEx categories under national GAAP.
• increased flexibility in the reporting of the OpEx
  Within the context of the Commission’s approach to simplify Taxonomy reporting, ESMA could explore ways to allow companies for which OpEx is material to select and report only those categories of OpEx that are relevant to their business (sector).

Where it feels it necessary, ESMA can also propose other targeted simplifications and improvements, for example, simplifying the reporting templates and related contextual information or proposing other changes to KPIs for non-financial undertakings and/or asset managers.

The EBA is invited to provide technical input on

• limiting the Commission and Fees KPI to capital markets-related activities
• connecting the Trading Book KPI to market liquidity
• narrowing the ‘other services’ KPI of investment firms
• five-year grandfathering period for financial exposures

Finally, EIOPA is invited to provide technical input on

• a revised methodology for Taxonomy-assessment of underwriting activities
• including climate-related perils in underwriting KPI.

In addition, each ESA (“in close cooperation and coordination with other ESAs”) is invited to provide technical advice on the following horizontal issues

• OpEx for the computation of the KPIs of financial institutions
• group level taxonomy reporting

Timing

The ESAs are expected to collect evidence and stakeholders’ views and draft the advice between March and September 2026.

Interim drafts and preliminary findings (including KPIs and associated methodology) are to be discussed with the Commission on a continuous basis.

The ESAs’ final advice is due to be finalised in October 2026.

The Commission is aiming to complete the review of the Disclosures Delegated Act by Q1 2027 and for the new measures to enter into force in Q3 2027 (i.e., before 31 December 2027, when the transitional relief for Taxonomy reporting which the Omnibus Delegated Act provides to financial undertakings expires).