EU Taxonomy Disclosures: EBA Advises Dropping Two Bank KPIs

On 29 October 2026 the European Banking Authority published its final report on EU Taxonomy disclosures (EBA/REP/2026/19), its answer to the European Commission’s call for technical advice on the Disclosures Delegated Act under Article 8 of the Taxonomy Regulation. The EBA advises the Commission to remove the Fees and Commissions KPI and the Trading Book KPI from the disclosure requirements, after testing the narrower capital-markets and market-making versions the Commission had asked it to explore and finding both wanting.

On publication day the law stays where it was. Commission Delegated Regulation (EU) 2021/2178, as amended by Delegated Regulation (EU) 2026/73, still governs the current cycle, and the two KPIs the EBA wants gone are already deferred to 1 January 2028. What moves is the planning picture. The Commission’s call for advice set Q1 2027 as its target for adopting amendments, and the EBA’s recommendations reach well beyond the two KPIs: Green Asset Ratio (GAR) templates, grandfathering, group-level KPIs and the investment-firm KPI that bank groups with securities businesses also disclose.

Pillar 3 teams have a second reason to read it. The EBA’s final draft ITS amending the Pillar 3 ESG templates, submitted to the Commission in June 2026, removes the GAR and BTAR templates from Pillar 3. Once that ITS is adopted and applies, the Annex VI templates discussed in this advice would be the only regulatory template set that carries a bank’s GAR.

Related reading: EU Taxonomy Disclosure Simplification: The 12 August ESMA Deadline

EU Taxonomy disclosures timeline: from the call for advice to 2028

• 4 March 2026: the Commission asks the three European Supervisory Authorities (ESAs) for targeted technical advice on the Disclosures Delegated Act (the date given in the EBA’s report and covering letter).
• 22 June 2026: the EBA submits its final draft ITS amending Commission Implementing Regulation (EU) 2024/3172, the Pillar 3 disclosure ITS, which drops Templates 6 to 9 (GAR and BTAR).
• 1 July to 12 August 2026: consultation on the EBA’s Discussion Paper on Taxonomy disclosures, with a public hearing on 16 July 2026.
• 28 October 2026: the EBA Chair’s letter to DG FISMA submits the final report; publication follows on 29 October 2026, the same date as ESMA’s final report on its part of the call.
• 31 December 2026: first reference date the EBA expects for the amending Pillar 3 ITS, with 31 December 2027 expected for small and non-complex institutions (SNCIs). Both remain subject to Commission adoption and any subsequent adjustments.
• Q1 2027: the Commission’s stated target for adopting amendments to the Disclosures Delegated Act, with entry into force aimed for Q3 2027.
• 31 December 2027: expiry of the transitional relief for Taxonomy reporting that the Omnibus Delegated Act provides to financial undertakings, as the Commission’s call describes it. The relief is conditional, with its conditions set in the amended Disclosures Delegated Act.
• 1 January 2028: application date for Annex V Sections 1.2.3 and 1.2.4, covering the Fees and Commissions KPI and the Trading Book KPI, under Article 10(5) of the Disclosures Delegated Act as amended by Delegated Regulation (EU) 2026/73. This date is not itself a filing deadline.

Only the last two dates come from adopted law. The Q1 and Q3 2027 targets are Commission planning statements, and the Pillar 3 dates hang on an implementing regulation that the EBA’s own page still lists as submitted to the Commission and not yet applicable.

Advice under Article 16a, with no legal text attached

The EBA delivered the report under Article 16a(4) of Regulation (EU) No 1093/2010, which allows it to give technical advice at the Commission’s request. That legal form matters for anyone trying to diff the proposal against current templates. The Commission’s call set out principles for the ESAs, and one of them, as the EBA’s report records, is that the technical advice takes no legal text form. There is no draft amending regulation to map; the Commission drafts that itself.

The three ESAs submitted separately. They coordinated common answers on the two horizontal questions, the use of counterparties’ OpEx and group-level reporting, so the EBA, ESMA and EIOPA texts should say the same thing on those points. ESMA’s final report on its own strand (ESMA32-846262651-5927) carries the same 29 October 2026 date and covers the OpEx KPI of non-financial undertakings. Bank KPIs currently draw on counterparties’ turnover and CapEx KPIs, and the OpEx question below asks whether that should change.

The evidence base is supervisory data. For credit institutions the EBA used FINREP returns from 125 institutions at the highest level of consolidation as of September 2025, identified as subject to CSRD, representing 64% of total assets (proxied by leverage ratio exposures). The EBA flags that the Bloomberg-based method used to identify CSRD-scope banks was under development and not final when the report was drafted. The report also summarises the feedback from the EBA’s public consultation in its annex, grouped by issue.

On scope, Directive (EU) 2026/470 amended the CSRD scope provisions in Articles 19a and 29a of the Accounting Directive. The revised individual and consolidated sustainability-reporting thresholds require both net turnover exceeding EUR 450 million and an average of more than 1,000 employees during the financial year, subject to the Directive’s application dates and national transposition. Whether a given bank sits inside that perimeter is a CSRD question, and the advice does not touch it.

Fees and Commissions KPI: narrowed on paper, then dropped

The Fees and Commissions KPI was meant to show how much of a bank’s fee income from services other than lending and asset management relates to Taxonomy-aligned activities of its counterparties. Article 10 of the Disclosures Delegated Act originally required it from 1 January 2026; Delegated Regulation (EU) 2026/73 pushed that to 1 January 2028. Its mandatory disclosure requirement has not yet begun to apply.

Its plumbing runs through FINREP. The KPI’s eleven service elements map onto rows of template F 22.01 on fee and commission income and expenses, which is why the report reads as much like a FINREP reporting document as a sustainability one. The mapping the EBA published, with the four elements it identified as capital-markets relevant:

The final report analyses a sample of 125 banks as of September 2025. With all eleven elements, fee and commission income from the services covered by the KPI exceeds 10% of net operating income for around 80% of credit institutions. Payment services drive most of that: excluding them, the share of institutions reaching the 10% line drops to 39%. Narrowed to the four capital-markets elements, the KPI’s aggregate share of net operating income falls to 5.9% for the sample, which the report puts at EUR 40 billion for the first nine months of the reference year.

The EBA’s July 2026 discussion paper, using the same September 2025 sample, put total fee and commission income at about EUR 157 billion (37% of total operating income), of which about EUR 94 billion came from the services in the KPI. These are separate sample statistics and are not reconciled here to a single denominator; they do not substitute for an institution’s own materiality test.

The EBA’s objections go beyond size. The KPI measures a flow that moves with pricing and deal volumes, so a bank that cuts fees to win Taxonomy-aligned mandates would report a lower ratio. Fee allocation across categories differs between banks. And with few issuances under the EU Green Bond Regulation, a narrowed KPI could expose the fee charged to a single client. The EBA advises removing the KPI.

As a fallback, the report sketches a simpler capital markets intermediation KPI the Commission “may consider”, covering elements (a), (c) and (d) only, with two ratios: the number of Taxonomy-aligned deals with eligible undertakings over all such deals, and the same comparison by aggregate deal value. A 10% materiality threshold on underlying transaction value could sit on top. Element (i), distribution, drops out of that sketch even though the EBA had counted it as capital-markets relevant.

One dependency sits outside the Taxonomy file. The EBA notes it is reviewing the FINREP module of Implementing Regulation (EU) 2024/3117, which could change the F 22.01 datapoints the KPI relies on, and some consultation respondents warned that deleting F 22.01 detail would cut the KPI’s data source. The two files run on separate timetables.

Trading Book KPI: market making tested, removal advised

The Trading Book KPI compares absolute purchases plus sales of Taxonomy-aligned debt securities and equity instruments, at fair value, with total purchases plus sales over the disclosure period. Alignment is estimated by weighting each counterparty’s instruments with that counterparty’s turnover and CapEx KPIs. Banks not required to disclose quantitative trading information provide qualitative information on the alignment of their trading portfolios instead, under Annex XI of the Disclosures Delegated Act. Like the fee KPI, it is deferred to 1 January 2028.

The Omnibus Delegated Act already changed who must compute it. It replaced the old significant-trading tests, which leaned on Articles 94(1) and 325a(1) of the CRR, with separate financial materiality provisions. A credit institution may omit a KPI where the cumulative net turnover generated by the activities it covers is below 10% of the institution’s total net turnover. Separately, it may omit assessing whether known-use-of-proceeds financial assets held for trading are Taxonomy-eligible or Taxonomy-aligned where their cumulative value is below 10% of all such assets included in the denominator of the KPI. The EBA report’s own summary sentence refers to activities of no more than 10% of total turnover and total assets, but the report’s next paragraph and the amended Disclosures Delegated Act set out the two separate tests described above.

The Commission asked the EBA to refocus the KPI on market making in Taxonomy-aligned securities. The EBA worked through the mechanics: the MiFID II definition of a market maker, the market making agreements required by Delegated Regulation (EU) 2017/578, and a possible ratio of Taxonomy-aligned instruments bound by such agreements over all instruments bound by them. It then advised removing the KPI; as an alternative, its executive summary says the Commission may consider a simpler KPI for credit institutions’ market making activities. Market making is one liquidity channel among several, trading positions are short-term, and the EBA judged that a point-in-time trading measure says little about how a bank allocates capital to sustainable activities.

The EBA puts the trading book of its 125-bank sample at about EUR 5 trillion, 22% of total assets, with debt securities and equity instruments at 39% of trading book assets. Only 21 institutions, 17% of the CSRD-scope sample, have a trading portfolio larger than 10% of their total assets. The legal materiality tests are the two in the amended Disclosures Delegated Act above; the 21-institution count is a sample statistic.

The advice to remove this KPI leaves the GAR’s perimeter where it is. The GAR is built on banking-book assets and excludes the trading book, which is covered by its own separate KPI, and nothing in the report moves held-for-trading positions into the GAR if the Trading Book KPI goes. The report is also silent on the Annex XI qualitative trading disclosure, which leaves its future an open question for the Commission’s draft.

Investment firms’ ‘other services’ KPI: four services and an asset-value metric

Investment firms disclose a KPI on revenue from investment services other than dealing on own account, which has a separate KPI. It covers reception and transmission of orders, execution, portfolio management, investment advice, underwriting and placing, and operating an MTF or OTF. The report notes that this KPI is relevant in practice for credit institutions and bank-led groups that provide investment services, as well as standalone investment firms.

Supervisory data for 141 investment firms put gross revenue from in-scope investment services at EUR 8.7 billion, of which over 18% (EUR 1.6 billion) came from dealing on own account. The ‘other services’ revenue is about EUR 7 billion, and portfolio management makes up 90% of it.

The EBA advises narrowing the KPI to four services where the firm can influence where capital goes:

• portfolio management;
• investment advice;
• underwriting or placing of financial instruments on a firm commitment basis;
• placing without a firm commitment.

It also recommends that the Commission consider replacing the revenue measure with one based on assets under management, as part of a wider review of the credit institutions’ off-balance-sheet KPI and the asset managers’ KPI, whose templates sit in Annexes VI and IV of the Disclosures Delegated Act.

The EBA advises the Commission to consider evaluating a harmonised methodology and templates across the three asset-management style KPIs. It does not recommend merging the bank AuM template into the asset managers’ template, and most respondents opposed an unconditional merger, citing different business models and the risk of double reporting. The report lists the open design questions itself: the share of discretionary versus non-discretionary mandates, business model differences, and keeping financial guarantees separate in the bank template.

Grandfathering: unlimited at origination, EuGB rules for EuGB bonds

Article 7(5) of the Disclosures Delegated Act, as amended by the Omnibus Delegated Act, lets financial undertakings keep reporting use-of-proceeds loans and instruments as Taxonomy-aligned, where they no longer meet amended technical screening criteria, until five years after the date of application of the delegated acts that amend those criteria. The EU Green Bond Regulation, Regulation (EU) 2023/2631, works differently. Its Article 8(1) has issuers allocate proceeds under the technical screening criteria applicable at issuance, and requires proceeds that are still unallocated or covered by a CapEx plan to meet amended criteria no later than seven years after those criteria apply. Article 8(2) sets a different rule for the portfolio approach, using the criteria that applied at any point in the seven years before the allocation report is published. The EBA reads the regulation as leaving already-allocated proceeds under the gradual approach outside the seven-year rule; that reading does not carry over to the portfolio approach.

The Commission asked whether the Taxonomy disclosure rules should follow the green bond approach. The EBA’s answer splits by instrument. Loans work differently from bonds here: a use-of-proceeds loan is assessed when the contract is concluded and its proceeds are earmarked at origination, whether or not they have been fully drawn. There is no unallocated pool to grandfather. Extending the green bond mechanics to every instrument would also force banks to collect post-issuance alignment updates bilaterally from counterparties that, outside the green bond framework, owe them no such reporting.

So the EBA advises the Commission to:

• delete Article 7(5) of the Disclosures Delegated Act;
• provide unlimited grandfathering for financial instruments assessed at origination as financing Taxonomy-aligned activities;
• align the grandfathering rules fully with the EU Green Bond Regulation for instruments issued under that Regulation.

Under the advice, the seven-year green bond mechanics would apply to European green bonds only; loans and other instruments with an origination-date alignment assessment would keep their aligned status without a time limit. Both regimes cover only instruments with known use of proceeds, which is why the origination-date evidence behind each use-of-proceeds exposure carries the weight. Our piece on EU green bond external reviewers and issuer reporting covers the issuer-side allocation reports that would anchor the bond leg.

OpEx stays out of financial undertakings’ KPIs

The Commission floated letting financial undertakings use, voluntarily, the OpEx KPI their non-financial counterparties report. The ESAs answered jointly and said no.

The EBA’s Box 3 shows what was on the table. A counterparty reports 18% Taxonomy-aligned CapEx and 32% aligned OpEx. Under current rules a bank lending to it uses 18%. With OpEx folded in, the bank could use a weighted 27%, or 32% for a short-term working-capital loan.

The ESAs’ objection is conceptual as well as practical: CapEx measures assets used over several years, OpEx measures what is consumed in the period, and blending them mixes investment with current spending. Add the cost, the loss of comparability between banks choosing differently, and greenwashing exposure, and the advice is not to introduce voluntary OpEx use in financial undertakings’ KPIs, in particular for credit institutions and investment firms.

The Box 3 percentages are an illustration of the rejected option. They set no expectation of a GAR uplift, and the GAR continues to rest on counterparties’ turnover and CapEx KPIs. How the OpEx KPI itself is defined for non-financial undertakings is ESMA’s part of the call; the EBA notes that the two questions are interrelated.

Group-level KPIs: the parent decides, no blended ratio

Annex V of the Disclosures Delegated Act ties a bank’s KPIs to its prudential scope of consolidation under Part One, Title II, Chapter 2, Section 2 of the CRR. Insurance and non-financial subsidiaries are typically equity-accounted and enter the GAR through the equity instruments line.

The report’s Box 5 walks through it. A bank-led conglomerate holds 40% of an insurer, bought for EUR 100 million. The insurer earns EUR 10 million, so the holding grows by EUR 4 million to EUR 104 million. If the insurer’s own Taxonomy alignment KPI is 3%, the bank’s GAR picks up EUR 3.1 million of aligned assets. Assets under management of asset-manager and investment-firm subsidiaries do not enter the GAR, because the clients own them.

The Commission’s third interpretative notice on the Disclosures Delegated Act (C/2024/6691, 8 November 2024) set out, in the EBA’s description, a single KPI for financial conglomerates and mixed groups: the weighted average of the KPIs of the group’s activities, weighted by each activity’s share of consolidated turnover. The notice interprets existing disclosure provisions and does not amend the Disclosures Delegated Act. The EBA’s analysis is that for bank-led groups this can overstate alignment: insurance activity is first equity-accounted inside the prudential perimeter and then included again in the weighted KPI on the basis of its turnover.

The ESAs advise removing the need for a weighted aggregate KPI. The main KPIs would follow the parent: for a group identified as a financial conglomerate under Directive 2002/87/EC, the KPIs relevant to the undertaking leading the conglomerate; for a financial holding company that is not a conglomerate, the regime for financial holding companies under Article 4(1)(20) CRR; otherwise, the non-financial rules. The current rules for credit institution-led groups would stay. On top, the EBA advises the Commission to consider secondary KPIs for a subsidiary, subject to three conditions:

• the subsidiary’s activities differ in nature from the parent’s;
• the net turnover from those activities is at least 10% of the group’s total net turnover;
• those activities are not already integrated in the consolidated disclosures with sufficient transparency.

The executive summary adds that activities serving exclusively intragroup needs would not trigger additional disclosure, and the report suggests the secondary information could take a simplified form compared with the full templates. The report does not specify that simplified form.

Annex VI GAR templates: Templates 3 and 4 flagged for removal, Template 1 reworked

Beyond the questions it was asked, the EBA passed on stakeholder points about the credit institution templates in Annex VI. Its advice is targeted:

The consultation feedback the EBA summarises included calls to remove Templates 2 to 7 as not decision-useful, and to drop non-eligible sectors from the GAR denominator. The EBA’s own advice stops at Templates 3 and 4 and the clarifications above. Template 1 is the one to watch: the household, local government and non-CSRD rows and the treatment of non-EU real estate are where any amended template would change data lineage.

Pillar 3 ESG disclosures lose the GAR and BTAR

The Pillar 3 ITS, Implementing Regulation (EU) 2024/3172, currently carries a copy of the Taxonomy story in Section 21 of Annex I: Template 6 (summary of GAR), Template 7 (assets for the GAR calculation, from Annex VI of the Disclosures Delegated Act), Template 8 (GAR KPI flow), Templates 9.1 to 9.3 (the banking book taxonomy alignment ratio, BTAR) and Template 10 (mitigating actions).

The EBA’s final draft amending ITS (EBA/ITS/2026/02, 22 June 2026) removes Templates 6 to 9 and any other datapoint on Taxonomy-aligned exposures, to avoid duplicating the Taxonomy Regulation disclosures. Template 4 on the top 20 carbon-intensive firms also goes, while Template 10 stays in revised form. At the same time the ITS implements CRR3’s version of Article 449a, which since 1 January 2025 requires all institutions, scaled by size and complexity, to disclose ESG risks. Our article on the CRR3 Pillar 3 ESG, equity and shadow banking ITS covers the three template sets and their reference dates.

Removing the GAR from Pillar 3 leaves the Article 8 obligation untouched. The two regimes also use different perimeters. The EBA’s Pillar 3 report distinguishes the prudential scope of Article 449a CRR from sustainability-reporting scope under the Accounting Directive.

Following Directive (EU) 2026/470, the revised EU sustainability-reporting scope under Articles 19a and 29a is based on net turnover and employee thresholds, subject to applicable transitional provisions and national transposition. It no longer uses a balance-sheet threshold as a general criterion for determining CSRD reporting scope. A bank outside the CSRD and Article 8 perimeter can therefore owe Pillar 3 ESG disclosures under Article 449a while owing no Taxonomy GAR.

Status on 30 October 2026: the EBA’s amending Pillar 3 ITS remains a draft submitted to the Commission, with no Official Journal reference, and Implementing Regulation (EU) 2024/3172 remains in force. EBA Opinion EBA/Op/2025/11, issued on 5 August 2025, recommends that competent authorities do not prioritise enforcement of specified Pillar 3 ESG disclosures pending entry into force of the revised ITS. For large listed institutions, the affected disclosures include ESG Templates 6 to 10 and specified Taxonomy-related columns in other templates; the opinion also addresses the expanded ESG requirements for other institution categories. The ECB has said it intends to follow the EBA’s recommendation. This is supervisory non-enforcement guidance, not repeal of the existing legal obligations, and institutions should check their competent authority’s position.

What the advice means for 2026 and 2027 build decisions

Three things are settled law today: the Disclosures Delegated Act as amended by Delegated Regulation (EU) 2026/73, the 1 January 2028 date for the Fees and Commissions and Trading Book KPIs, and the current Pillar 3 ITS. Everything else in this report is a recommendation to the Commission, which has said it intends to adopt amendments in Q1 2027.

Bank workstreams divide into two groups under this advice. Work that the advice leaves intact keeps its value: origination-date alignment evidence for use-of-proceeds exposures, clean mapping of Template 1 rows 11, 15 and 25, an EU and non-EU flag on real estate collateral, and a list of subsidiaries whose activities differ from the parent’s and reach 10% of group net turnover. Work tied to the two deferred KPIs, and to blending OpEx into the GAR, faces the EBA’s advice to remove or not introduce it. How far to go with the second group before the Commission publishes a draft is a judgement each bank makes against its own 2028 readiness, and the report does not settle it.

Frequently Asked Questions

Do the EBA’s materiality figures tell us whether our own Fees and Commissions KPI would be material?

Only loosely. FINREP carries no turnover figure, so the EBA measured against net operating income as a proxy. The Disclosures Delegated Act’s own tests use the bank’s total net turnover and, at the second layer, the share of fee and commission income tied to specific economic activities, each with a 10% line. The sample also relied on a CSRD identification method the EBA describes as not final. Any bank-level conclusion needs the bank’s own turnover figures.

We are a subsidiary included in our parent’s consolidated management report. Do we produce our own Article 8 KPIs?

Article 19a(9) of the Accounting Directive (Directive 2013/34/EU, as amended) permits qualifying subsidiaries to be exempt from individual sustainability reporting where they are included in a parent’s consolidated sustainability reporting and satisfy the exemption conditions. Those conditions include identifying the reporting parent, providing the required links to its consolidated report and assurance opinion, and stating the exemption in the subsidiary’s management report.

Directive (EU) 2026/470 replaced Article 19a(10) so that the Article 19a(9) exemption also applies to public-interest entities subject to Article 19a, without the earlier carve-out for large listed public-interest entities. The amendment is subject to national transposition, due by 19 March 2027, so an institution’s entitlement to the exemption for a particular reporting period must be assessed under the applicable national legislation and transitional arrangements.

Where the parent is established in a third country, Article 8 Taxonomy disclosures covering the exempted EU subsidiary must still be included in the subsidiary’s management report or the third-country parent’s consolidated sustainability reporting. The exemption must therefore be assessed against the applicable legal conditions and national implementation, and cannot be presumed from consolidation alone. Article 29a(4) requires the parent to give an adequate understanding of subsidiaries whose risks or impacts differ significantly. The EBA’s advice on secondary KPIs concerns how the group report is built; it does not propose changing the exemption.

We hold European green bonds in the banking book. Which grandfathering rule would apply under the advice?

For instruments issued under Regulation (EU) 2023/2631, the advice is full alignment with that Regulation’s Article 8, which runs on the issuer’s allocation and its allocation report. Other use-of-proceeds instruments assessed as aligned at origination would get unlimited grandfathering. Until the Commission amends the Disclosures Delegated Act, the five-year rule in Article 7(5) applies to both.

If the Fees and Commissions KPI goes, can we simplify our FINREP F 22.01 feed?

F 22.01 is a supervisory reporting requirement under Implementing Regulation (EU) 2024/3117 in its own right. Removing the Taxonomy KPI would take away one downstream use of the data; the FINREP obligation would stay as the FINREP ITS defines it. Changes to F 22.01 itself belong to the EBA’s separate reporting simplification work, which the EBA consulted on until 10 July 2026.

Our bank is classified as an SNCI. Does the Pillar 3 change mean we never need a GAR?

The EBA’s draft Pillar 3 amendment would remove the GAR templates from prudential disclosure once adopted and applicable. The EBA expects the first ESG reference date for SNCIs under the revised ITS to be 31 December 2027, subject to Commission adoption and any subsequent changes. Whether an SNCI owes a Taxonomy GAR depends on whether it falls within the CSRD and Article 8 perimeter, which is tested on different criteria from the CRR size classes.

Does the advice say anything about insurance subsidiaries’ underwriting KPI?

The underwriting KPI belongs to EIOPA’s part of the call. For a bank-led conglomerate, the EBA’s point is about presentation: the insurance stake stays equity-accounted in the GAR, and where the insurance business is material, additional information on that subsidiary may be needed to show the group’s Taxonomy profile, subject to the secondary-KPI conditions.

Related Articles

• EU Taxonomy Disclosure Simplification: The 12 August ESMA Deadline: the July 2026 consultations by ESMA, the EBA and EIOPA that fed into this advice.
• CRR3 Pillar 3 Disclosure Update: ESG, Equity and Shadow Banking: the June 2026 final draft ITS that removes the GAR and BTAR templates from Pillar 3.
• EBA ESG Pillar 3 Disclosure Templates: how the Article 449a ESG templates under Implementing Regulation (EU) 2024/3172 are structured.
• EBA Supervisory Reporting Simplification: the EBA’s 2026 consultation on simplifying supervisory reporting templates, the workstream that also covers FINREP.
• Revised ESRS and Simplified CSRD Reporting: the revised ESRS and simplified CSRD sustainability reporting for 2026.

Key Takeaways

• Spend on the Fees and Commissions and Trading Book KPIs is a decision to take before Q1 2027: both are still due from 1 January 2028 in law, and the EBA has advised removing both.
• Record a dated alignment assessment at origination for every use-of-proceeds loan; under the advice, that assessment is what would earn unlimited grandfathering.
• Flag instruments issued under the EU Green Bond Regulation separately in the GAR data model, because the advice routes them to that Regulation’s grandfathering rules.
• Map Template 1 rows 11, 15 and 25 and flag real estate assets as EU or non-EU: the EBA advises the Commission to consider clarifying those rows and either excluding non-EU real estate from the GAR or adding separate EU and non-EU datapoints. Templates 3 and 4 are the only Annex VI templates the EBA advises the Commission to consider deleting.
• Build the group perimeter test now: subsidiaries of a different nature with at least 10% of group net turnover are the candidates for secondary KPIs, and the turnover-weighted group KPI is the piece the ESAs want removed.
• Plan year-end 2026 Pillar 3 ESG disclosures against the in-force Implementing Regulation (EU) 2024/3172, EBA Opinion EBA/Op/2025/11 and the institution’s competent authority position. Separately, prepare for the draft ITS’s expected first reference date of 31 December 2026, or 31 December 2027 for SNCIs, subject to Commission adoption and any subsequent changes.
• Leave OpEx out of GAR models; the ESAs advised against voluntary OpEx use in financial undertakings’ KPIs.

Sources and References

• EBA, press release, 29 October 2026: The EBA advises on targeted simplifications to Taxonomy disclosures
• EBA, Report on certain Taxonomy key performance indicators and other aspects of the Disclosures Delegated Act under Article 8 of the Taxonomy Regulation, EBA/REP/2026/19, October 2026: Report on Taxonomy disclosures (PDF)
• EBA Chair, letter to DG FISMA submitting the final report, 28 October 2026: Letter to DG FISMA (PDF)
• European Commission, DG FISMA, Call for technical advice to the ESAs on certain Taxonomy KPIs and other aspects of the Disclosures Delegated Act (Ref. Ares(2026)2366154): Call for technical advice (PDF)
• EBA, Discussion on technical advice on selected KPIs under the Taxonomy Disclosures Delegated Act (consultation 1 July to 12 August 2026): EBA discussion page
• ESMA, Final Report on Technical Advice on selected KPIs under the Taxonomy Disclosures Delegated Act, ESMA32-846262651-5927, 29 October 2026: ESMA final report (PDF)
• Regulation (EU) 2020/852 (Taxonomy Regulation): EUR-Lex
• Commission Delegated Regulation (EU) 2021/2178 (Disclosures Delegated Act): EUR-Lex
• Commission Delegated Regulation (EU) 2026/73 of 4 July 2025 (Omnibus Delegated Act), OJ L, 2026/73, 8.1.2026: EUR-Lex
• European Commission, Taxonomy Regulation delegated acts page (publication record for Delegated Regulation (EU) 2026/73): DG FISMA
• Commission Notice C/2024/6691 on the interpretation and implementation of certain legal provisions of the Disclosures Delegated Act (third notice): EUR-Lex
• Regulation (EU) 2023/2631 (European Green Bonds Regulation): EUR-Lex
• Regulation (EU) No 1093/2010 (EBA Regulation), Article 16a: EUR-Lex
• Regulation (EU) No 575/2013 (CRR), including Article 449a as amended by Regulation (EU) 2024/1623: EUR-Lex
• Commission Implementing Regulation (EU) 2024/3172 (Pillar 3 disclosure ITS): EUR-Lex
• Commission Implementing Regulation (EU) 2024/3117 (supervisory reporting ITS, including FINREP): EUR-Lex
• EBA, Final Report on draft ITS amending Implementing Regulation (EU) 2024/3172 as regards ESG risks, equity exposures and shadow banking entities, EBA/ITS/2026/02, 22 June 2026: Final report (PDF) and EBA ITS page (status)
• EBA, Opinion EBA/Op/2025/11, 5 August 2025 (no-action letter on the application of the ESG Pillar 3 disclosure requirements), and ECB Banking Supervision, ESG FAQ on the EBA no-action position: ECB FAQ
• EBA, Final Report on IFRS 18 implementation in FINREP, Annex 1 (on F 22.01 and the reporting simplification consultation): EBA (PDF)
• Commission Delegated Regulation (EU) 2017/578 (market making agreements and schemes): EUR-Lex
• Directive (EU) 2026/470 (amending the CSRD scope provisions of Directive 2013/34/EU): EUR-Lex
• Directive 2013/34/EU (Accounting Directive), Articles 19a and 29a as amended by Directive (EU) 2022/2464: EUR-Lex and CSRD on EUR-Lex
• Directive 2002/87/EC (Financial Conglomerates Directive): EUR-Lex

Next decision point: the Commission’s Q1 2027 amendment

The EBA and ESMA final reports are now public, and the next primary document is the Commission’s draft amendment to Delegated Regulation (EU) 2021/2178, targeted for adoption in Q1 2027 and entry into force in Q3 2027. When it appears, the first checks are whether Article 10 still lists the Fees and Commissions and Trading Book KPIs with a 1 January 2028 date, whether Article 7(5) survives, and what Annex VI Template 1 looks like. For Pillar 3, the date to watch is Official Journal publication of the regulation amending Implementing Regulation (EU) 2024/3172 ahead of the EBA’s expected 31 December 2026 reference date.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.