EU Platform on Sustainable Finance responds to Commission's consultation on the Taxonomy Disclosures Delegated Act

The EU Platform on Sustainable Finance has published its response to the European Commission’s consultation on the Taxonomy Disclosures Delegated Act.

Background

In March 2026, the Commission sent the European Supervisory Advisors (ESAs) a call for technical advice to inform the review of the Disclosures Delegated Act under the Taxonomy Regulation (see our earlier blog post). To deliver on the call for advice, ESMA launched a consultation in July 2026 (see our earlier blog post). 

The Platform has now published its response setting out its views which serves as a preamble to the full report that will be submitted to the European Commission in December 2026. That report will cover additional issues beyond the ESAs' consultation, such as environmental objectives reporting.

Recommendations

The Platform makes four main recommendations:

• Adoption of a two-tier approach for the operational expenditure (OpEx) KPI, consisting of
  • a mandatory OpEx KPI limited to R&D expenditure; and
  • a voluntary opt‑in broader OpEx KPI based on the current denominator for companies wishing to disclose additional transition‑related operational expenditure;
     
• Removal of the weighted-average consolidated KPI  group reporting. If a single KPI is required, the KPI arising from the group's main reporting regime should be used, with the regime to be determined based on the group's prevalent activity;
   
• Incorporation of climate change adaptation clarifications directly into the Disclosures Delegated Act, as suggested by ESMA; and 
   
• Maintaining the CapEx type C mandatory. The Platform is working on a proposal to improve its definition by clarifying its scope and application.

The press release published on 22 September 2026 is available here.