EU: ESAs to provide technical advice on the Taxonomy Disclosures Delegated Act

The European Commission has issued a call for technical advice inviting the European Supervisory Authorities (ESAs) to develop technical advice to inform the Commission’s review of the Disclosures Delegated Act under Article 8 of the Taxonomy Regulation.

The Commission has asked that the advice should focus on the following Key Performance Indicators (KPIs):

• 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 necessary to the Disclosure Delegated Act to simplify and enhance the usability of Taxonomy reporting.

Background

The call for advice notes that the EU Omnibus Delegated Act published in January 2026 has already simplified Taxonomy reporting, significantly reduced the number of datapoints to be reported, postponed reporting of certain KPIs by banks, and streamlined the ‘do not significant harm’ criteria on the use of chemicals.

The current review is to focus on measures that were not included in the Omnibus Delegated Act due to their technical nature, and will take place alongside ongoing work to amend the SFDR. This  suggests that the Commission is not contemplating more substantive simplification measures but rather on targeted measures to supplement the measures under the Omnibus Delegated Act.

Scope of the exercise

Non-financial undertakings

The call for advice notes that whilst the turnover and capital expenditure (CapEx) KPIs covering companies’ revenues and longer-term investments are 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 considered to be of limited use and too burdensome since it does not consider the different importance of various operating expenditures in different economic sectors.

Financial undertakings

The Omnibus Delegated Act has already addressed the need for simplification of the Green Asset Ratio (GAR) of banks and the investment KPIs (GIR) of other financial undertakings by excluding, as a rule, their exposures to SMEs. The call for advice suggests that to complete the review of the Disclosures Delegated Act, the changes should focus on simplifying the remaining KPIs of financial undertakings that are considered as burdensome and less relevant than the GAR/GIR, in particular: the Commissions and Fees KPI and the Trading Book KPI of banks and the underwriting KPI of insurance companies. 

Areas of focus for each ESA

ESMA is invited to provide technical input on:

• broadening the scope of the OpEx KPI denominator: 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: wherever possible, the identified OpEx categories should reference international accounting standards, which would facilitate the identification of the OpEx covered by the reporting. 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 simplified approach to 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).

The EBA is invited to provide technical input on:

• limiting the Commission and Fees KPI to capital markets-related activities: the EBA could explore ways to narrow down the scope of the Commission and Fees KPI to activities related to capital markets, such as those related to securities issuance, M&A and corporate finance and services supporting the issuance and trading of green (Taxonomy-aligned) securities (reception, transmission and execution of orders, clearing and settlement, custody).

• connecting the Trading Book KPI to market liquidity: the EBA could explore ways to narrow down the scope of the Trading Book KPI to providing market liquidity through market making, with a clear focus on providing liquid markets for green (Taxonomy aligned) securities.

• narrowing the ‘other services’ KPI of investment firms: the scope of the ‘other services KPI’ of investment firms could be narrowed down in line with the Commission and Fees KPI of credit institutions.

• five-year grandfathering period for financial exposures in terms of compliance with Taxonomy criteria (in case criteria are revised and the investee company does not comply with new rules): the EBA could in cooperation with ESMA and EIOPA explore ways to align rules with the approach under the EU Green Bonds Standard 

EIOPA is invited to provide technical input on:

• a revised methodology for Taxonomy-assessment of underwriting activities: this could explore how to develop a revised methodology for the Taxonomy assessment of non-life underwriting activities.

• including climate-related perils in underwriting KPI: to explore whether a revised underwriting KPI should be supplemented by information on underwriting of climate related perils based on the Technical Screening Criteria for this activity laid down in Annex II to the Climate Delegated Act.

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

Timings

The Commission asks for the final advice to be delivered by October 2026.

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

The call for technical advice published on 5 March 2026 is available here.