On 22 September 2026, the EU Platform on Sustainable Finance published its response to the European Commission (Commission) Consultation on the Taxonomy Disclosures Delegated Act.

Background

On 4 March 2026, the Commission sent the European Supervisory Authorities (ESAs) a call for technical advice to inform the review of the Disclosures Delegated Act under the Taxonomy Regulation. To deliver on the call for advice, on 1 July 2026, the European Securities and Markets Authority (ESMA) launched a consultation seeking stakeholders’ views on certain topics. The consultation covered four topics: revising the operating expenditure key performance indicator (OpEx KPI); the voluntary use of OpEx by financial undertakings (a horizontal issue); group Taxonomy reporting (also horizontal); and additional possible simplifications.

In this context, the Platform on Sustainable Finance, an advisory body to the Commission, has published its response setting out its views on the issues covered by ESMA’s consultation. The response has been transmitted to ESMA and serves as a preamble to the full report the Platform will submit to the Commission on the review of the Taxonomy Disclosures Delegated Act in December 2026.

Recommendations

In the response, the Platform make four main recommendations

  • OpEx KPI:  adopting a two‑tier approach consisting of a mandatory OpEx KPI limited to research and development expenditure and a voluntary opt‑in broader OpEx KPI based on the current denominator for companies wishing to disclose additional transition‑related operational expenditure.
  • Group reporting:  removing the weighted‑average consolidated KPI. 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.
  • Adaptation: incorporating the climate change adaptation clarifications directly into the Disclosures Delegated Act, as suggested by ESMA maintaining the CapEx type C mandatory. The Platform is working on a proposal to improve its definition by clarifying its scope and application.