EFRAG Agenda Consultation 2027-2029: The 15 February 2027 Deadline

On 16 October 2026, EFRAG launched a public consultation on its sustainability reporting agenda: a Request for Input (RFI) covering its work from mid-2027 to the end of 2029, with responses due by 15 February 2027. In the EFRAG agenda consultation, EFRAG says it expects no new standard-setting activity from 2027 to 2029 after it finalises its ESRS-40a technical advice, which the RFI expects at the beginning of 2027, and proposes putting half of its sustainability reporting capacity into implementation support.

The proposal changes how a preparer gets an answer out of EFRAG. A monitoring system would replace the implementation Q&A mechanism, and EFRAG will only add an implementation issue to the workplan where there is clear demand from preparers or other stakeholders (RFI paragraph 50). That demand can come from this consultation or from the monitoring mechanism, which does not yet exist (paragraph 22). Banks have their own question: whether EFRAG should run a channel, optionally confidential, through which companies outside mandatory reporting send them reports prepared under the Voluntary Standard (VS).

Related reading: ESRS Knowledge Hub: EFRAG’s 2026 Revised Standards, Mapped

Key dates in the EFRAG agenda consultation

• 16 October 2026: RFI, online questionnaire and PDF copy of the questionnaire published.
• 10 November 2026: Commission Delegated Regulation (EU) 2026/1563 enters into force. Financial years beginning on or after 1 January 2027: the revised ESRS in that regulation apply.
• Last quarter of 2026: preliminary outreach meetings on early implementation issues, pending the monitoring system (paragraph 42).
• January 2027: EFRAG expects to submit its final ESRS-40a technical advice to the European Commission. The Commission’s subsequent consultation and adoption are separate steps, with no confirmed adoption date.
• 15 February 2027, 6pm CET: online questionnaire closes. Comment letters are also accepted by email to SRagenda@efrag.org.
• First half of 2027: feedback discussed at public meetings; a Feedback Statement follows (paragraph 11).
• Second quarter of 2027: 2027-2029 workplan expected, following approval by the EFRAG Sustainability Reporting Board (SRB).

The window opens at mid-2027 because EFRAG’s current voluntary-reporting and Knowledge Hub deliverables sit under a Commission grant for Pilot Project PP 03 24 02, which runs until then (paragraph 6). The consultation itself is a due process requirement: the SRB must consult on its activities and workplan every three years (paragraph 4).

Zero for standard setting, 50% for implementation support

Table 2 of the RFI sets the proposed balance of activities from July 2027 to the end of 2029 in tentative full-time-equivalent Secretariat resources (paragraph 36). The questionnaire reproduces it for survey Question 17 (RFI Question 1(d)), where respondents mark each row agree, increase or decrease.

The two documents disagree on the first row. The RFI allocates 0% to standard setting, so its column adds up to 95%; the questionnaire shows 5% beside the same rationale, and neither comments on the difference. A response on that row is clearer if it names the figure it is answering.

Two qualifications sit next to the zero. If the Commission requests urgent amendments, EFRAG will re-assess priorities and take capacity from research, keeping at least 5% there (Table 2 and paragraph 64). The post-implementation review should not start before 2030 for the 2026 revised ESRS, or before 2031 for the VS (paragraph 19).

Sector guidance is the open item. Recital 20 of the Omnibus I Directive, Directive (EU) 2026/470, explains that the Commission’s empowerment to adopt sector-specific reporting standards should be deleted and that the Commission could support undertakings with sector-specific guidance. EFRAG’s allocation does not anticipate significant resources for that work, and EFRAG says it will adjust the allocation depending on consultation feedback (paragraph 23).

The 15% international line covers draft comment letters on ISSB (including SASB), GRI and GHG Protocol consultations (paragraph 21). EFRAG says it could realistically focus research on one, or possibly two, issues in 2027-2029, from a list that includes how AI changes the preparation and use of sustainability information (paragraphs 59 and 61).

The Q&A mechanism gives way to a monitoring system

Section B proposes a four-step implementation support system: collect needs, decide which to address, develop the deliverable under due process, deliver it. The monitoring system would draw on the three-yearly agenda consultation, a Knowledge Hub platform with standardised submission forms, a public log of requests and their status, stakeholder voting or ranking, and outreach meetings with key stakeholders once a year or more (Table 3). EFRAG describes its posture as “in the listening mode” and does not intend to create the expectation that every question will be answered (paragraph 43).

A standard-setting notice flags an issue that needs an amendment EFRAG cannot make without standard setting initiated by the Commission; a clarification explains what a requirement asks for without interpreting it. Both need SR TEG and SRB approval and a 60-day public consultation. Implementation resources and educational material follow lighter approval and consultation routes (paragraph 47), and all these deliverables are non-mandatory (paragraph 48). For time-sensitive material, EFRAG proposes to avoid final publications between October and February, when companies prepare the sustainability statement (paragraph 45(b)).

The existing guidance stays in the Knowledge Hub, unrevised. EFRAG does not intend to update Implementation Guidance 1 on double materiality, Implementation Guidance 2 on value chain or the compilation of Q&A explanations, which remain supporting documents for ESRS as adopted in 2023; the list of datapoints, formerly IG 3, is the exception and is being finalised in 2026 (paragraphs 51 and 52). A double materiality methodology that cites IG 1 would get no revised-ESRS edition of it under this proposal, and RFI Question 2(b) asks whether respondents agree.

Table 4: the ESRS themes preparers are asked to rank

RFI Question 3(b), Question 27 in the online survey, asks for a high, medium or low priority on each of the 16 themes in Table 4, a tentative list drawn from comments on the Commission’s public consultation on revised ESRS, EFRAG’s 2025 simplification work and April 2026 interviews (footnote 13).

Cross-cutting themes include fair presentation in double materiality reporting; how the reliefs in sub-chapters 5.4, 7.3, 7.4 and 7.7 of ESRS 1 interact, including the undue cost or effort judgement; combining top-down and bottom-up materiality assessment; and disclosure of AI use in preparing the report. Topical themes range from the interaction of the environmental standards with the Taxonomy Regulation and, for E1, the EU ETS and CBAM, to the S1-9 and S1-15 adequate wage and remuneration metrics and cybersecurity as an entity-specific disclosure.

Anticipated financial effects are absent by design: EFRAG already started AFE work under its 2026 workplan and intends to continue it with the ISSB (paragraph 53). A genuinely missing theme goes in the free-text field after the ranking.

The VS repository question for banks and lenders

EFRAG expects to spend the first 12 months of the new workplan focused on voluntary reporting, reassessing resources from month 12 (paragraph 37). The standard is already adopted: Commission Delegated Regulation (EU) 2026/1560 of 3 July 2026, published on 21 September 2026, establishes the VS and the value chain cap, with the cap article applying from financial years beginning on or after 1 January 2027. Our guide to the EU Voluntary Sustainability Reporting Standard covers the modules and the cap.

A VS report built with EFRAG’s digital template can today be produced and downloaded, but not stored or shared with counterparties (paragraph 30). EFRAG is implementing a repository in the Knowledge Hub and asks whether to add a distribution hub for sending VS reports to banks, investors and business partners, publicly or confidentially. No decision has been taken on EFRAG operating in a distribution capacity (footnote 9). The hub would need resources beyond the ordinary grant, with contributions from institutional users such as banks among the listed options; submission would stay voluntary and free of charge for companies (paragraph 30).

ESAP is a separate channel. Under Article 3(1) of Regulation (EU) 2023/2859, from 10 January 2030 an entity may submit the information referred to in Article 1(1), point (b), to the collection body in the Member State where it has its registered office, for the purpose of making that information accessible on ESAP, subject to the conditions in that paragraph on scope, metadata, data-extractable format and personal data. Our ESAP first-phase explainer covers the mandatory flows already scheduled.

For a lender, RFI Questions 1(c)(i) to (iii), survey Questions 14 to 16, are where to state a view on the hub and on connecting national platforms. Paragraph 32(g) adds a possible project with users such as banks to standardise client data requests starting from the VS. The other new population is larger companies scoped out by Omnibus I: the Secretariat estimates more than 10,000 companies with over 750 employees and either turnover below EUR 450 million or fewer than 1,000 employees (footnote 6), and EFRAG could extend support to them if the consultation confirms sufficient demand (paragraph 25).

Responding: survey numbering and publication

The online survey has 39 numbered items, nine on the respondent and 30 on substance, and its numbering does not follow the RFI. Preparers classify themselves in item 7: in scope of mandatory ESRS, a third-country undertaking (or EU subsidiary or branch) in scope of ESRS-40a, a non-SME outside the CSRD scope, or an SME. Only responses sent with the Submit button count. On publication, the RFI says comments will be published unless confidentiality is requested (paragraph 9), and EFRAG’s open consultations page adds that such requests will not normally be granted without good reason, such as commercial confidence; the survey says a respondent who withholds consent will have its feedback treated anonymously.

Frequently Asked Questions

Does responding change anything in our FY2026 or FY2027 ESRS reporting?

No. Responding to EFRAG’s consultation does not amend companies’ reporting obligations. Commission Delegated Regulation (EU) 2026/1563 was published on 21 September 2026 and enters into force on 10 November 2026. It applies to financial years beginning on or after 1 January 2027. Article 2 provides transitional choices for financial years starting in 2026: the previous ESRS as last amended by Regulation (EU) 2025/1416, the revised ESRS, or the previous ESRS combined with the eight specified ESRS 1 reliefs from the revised standards. Undertakings using these transitional provisions must identify the version applied in their sustainability statement.

We are a non-EU group expecting ESRS-40a reporting. Is this consultation relevant to us?

EFRAG explicitly encourages stakeholders outside the EU to respond on ESRS-40a implementation support and interoperability, and RFI Question 3(c) asks for priority ESRS-40a issues. EFRAG states that ESRS-40a will apply to approximately 1,200 companies (paragraph 70). Our ESRS-40a explainer covers the scope and reporting trigger.

What happens to a question we raised on the ESRS Q&A platform that was never answered?

EFRAG does not intend to address questions left unanswered from the previous Q&A process (paragraph 52). An issue that still matters under revised ESRS would need raising again, through this consultation’s free-text fields or the monitoring system once it exists.

Related Articles

• Revised ESRS: The 60% Datapoint Cut Facing CSRD Reporters: what the revised ESRS change for companies still in CSRD scope.
• EU Voluntary Sustainability Reporting Standard: Scope, Modules, Cap: the VS modules and how the value chain cap limits data requests.
• ESRS-40a for Non-EU Undertakings: The FY2028 Reporting Trigger: EFRAG’s draft standard for third-country groups and its timing.
• EFRAG 2026 Draft ESRS Datapoints List: The 23 October Deadline: the datapoints list that succeeds IG 3 for revised ESRS.
• ESAP First Phase: Where Regulated Disclosures Must Now Be Filed: the first mandatory flows into the European Single Access Point.

Sources and References

• EFRAG, “EFRAG Launches Public Consultation on Its Sustainability Reporting Agenda for 2027-2029” (16 October 2026): efrag.org
• EFRAG, Agenda Consultation 2027-2029, Request for Input (October 2026): efrag.org (PDF)
• EFRAG, Agenda Consultation 2027-2029, Online Questionnaire, PDF version (October 2026): efrag.org (PDF)
• EFRAG, 2027-2029 Agenda Consultation online survey: survey.alchemer.eu
• EFRAG, Open consultations (publication and confidentiality terms): efrag.org
• EFRAG, “EFRAG Launches Public Consultation on the ESRS-40a Exposure Draft for Certain Non-EU Undertakings” (23 July 2026): efrag.org
• Directive (EU) 2026/470 of 24 February 2026 (Omnibus I Directive): eur-lex.europa.eu
• Commission Delegated Regulation (EU) 2026/1560 of 3 July 2026 (Voluntary Standard): eur-lex.europa.eu
• Commission Delegated Regulation (EU) 2026/1563 of 3 July 2026 (revised ESRS): eur-lex.europa.eu
• Regulation (EU) 2023/2859 establishing a European single access point: eur-lex.europa.eu

What to have ready for EFRAG by 15 February 2027

The survey closes at 6pm CET on 15 February 2027. A useful response from a reporting team carries a high, medium or low ranking for each Table 4 theme it actually reports against, with missing themes written in; a position on each Table 2 row that names the standard-setting figure it is answering; and, for banks collecting VS data, a view on the distribution hub and whether they would connect to it. The 2027-2029 workplan is expected in the second quarter of 2027, after SRB approval.

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