EU Taxonomy KPIs: ESMA’s Final Advice Narrows OpEx to R&D

On 29 October 2026 ESMA sent the European Commission its Final Report on technical advice on selected EU Taxonomy KPIs under the Disclosures Delegated Act (ESMA32-846262651-5927). The Commission’s call for that advice says it intends to adopt amendments to Delegated Regulation (EU) 2021/2178 in Q1 2027, which makes the report a direct input into how Article 8 disclosures by listed non-financial undertakings and asset managers could change in later reporting years.

The recommendations land differently depending on who files. Listed issuers would see the mandatory OpEx KPI narrowed to non-capitalised research and development (R&D) expenditure, and would gain a set of optional reliefs. Asset managers get close to a standstill: ESMA advises no further change to the asset-management annex until the review of the Sustainable Finance Disclosure Regulation (SFDR) settles, and the three European Supervisory Authorities (ESAs) jointly advise against letting financial undertakings blend investee OpEx into their KPIs. Mixed groups, including groups that hold asset managers or investment firms, would lose the weighted-average group KPI in favour of a parent-led main reporting regime.

The advice has no legal effect of its own. Delegated Regulation (EU) 2021/2178 as amended by Delegated Regulation (EU) 2026/73 still governs current reporting. The KPI that investment firms report on their own services is handled in the EBA’s parallel final report, which invites a broader review of asset-based KPIs that ESMA would postpone.

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

From call for advice to amending act: the operative dates

The Final Report closes a process that began with the Omnibus I simplification package. The last two entries below are Commission targets, so treat them as planning dates.

• 8 January 2026: Delegated Regulation (EU) 2026/73 of 4 July 2025 (the Omnibus Delegated Act) published in the Official Journal. It applies from 1 January 2026, and undertakings could keep applying the earlier Disclosures, Climate and Environmental Delegated Acts for financial years starting between 1 January and 31 December 2025, as the Malta Financial Services Authority’s 13 January 2026 circular summarises.
• 4 March 2026: the Commission’s call for technical advice to the ESAs (Ares(2026)2366154), requesting final advice by October 2026.
• 30 April 2026: the Fourth Commission Notice (C/2026/2558), with FAQs on the Disclosures Delegated Act as amended by the Omnibus Delegated Act.
• 1 July to 12 August 2026: ESMA’s consultation (ESMA32-846262651-5826), with a public hearing on 22 July 2026.
• 28 October 2026: the EBA Chair’s letter submitting the EBA’s final report (EBA/REP/2026/19) to the Commission.
• 29 October 2026: ESMA’s Final Report and press release.
• Q1 2027 (target): Commission adoption of amendments to the Disclosures Delegated Act.
• Q3 2027 (target): entry into force. The Commission aims for entry into force in Q3 2027, before the transitional relief for qualifying financial undertakings ends on 31 December 2027.

Two details shape how to read the rest. The call’s principles asked the ESAs for advice that is not drafted as legal text, so the paragraph numbering in the report is ESMA’s own and the Commission will write its own provisions. ESMA’s discussion of the cost-benefit feedback also records a request from some respondents that every amendment to the Disclosures Delegated Act arrive in one amending act with a single application date. Whether the Commission bundles the changes that way is still open.

ESMA’s positions on EU Taxonomy KPIs at a glance, and who each one reaches

ESMA’s remit in this exercise covers non-financial undertakings listed on EU regulated markets and asset managers. The report adds that neither the Taxonomy Regulation nor the amended Corporate Sustainability Reporting Directive (CSRD) distinguishes by listing status, so its considerations for listed issuers extend to non-listed non-financial undertakings within scope. Banks and investment firms sit with the EBA and insurers with EIOPA. The two horizontal topics, investee OpEx in financial undertakings’ KPIs and group reporting, were developed jointly by all three ESAs.

Whether any row reaches a given entity depends first on whether it reports under Article 8 at all. The Taxonomy Regulation attaches its obligations to undertakings that must publish sustainability information under Article 19a or 29a of the Accounting Directive (Directive 2013/34/EU). Directive (EU) 2026/470 amended Articles 19a and 29a of the Accounting Directive to set sustainability reporting thresholds of more than 1,000 employees on average and net turnover exceeding EUR 450 million, assessed on a consolidated basis for qualifying parent undertakings. For financial years beginning in 2025 or 2026, however, Article 3 of Directive (EU) 2026/470 allows Member States to exempt certain previously in-scope undertakings. Reporting teams must therefore assess the applicable financial year and national implementing provisions before concluding that an undertaking is outside Article 8 reporting.

The OpEx KPI narrowed to non-capitalised R&D

Article 8(2) of the Taxonomy Regulation names three KPIs for non-financial undertakings: Turnover, CapEx and OpEx. Several respondents wanted OpEx deleted or made voluntary. ESMA’s answer is that recommending changes to requirements set in the Regulation itself falls outside the scope of technical advice. The KPI therefore survives, in a much smaller form.

ESMA recommends that the mandatory OpEx KPI focus on non-capitalised R&D expenditure. The denominator would be the R&D expenses recognised under IAS 38 Intangible Assets, or under the relevant national GAAP for non-IFRS reporters. The numerator would keep the expenditure categories already in point 1.1.3.2 of Annex I to the Disclosures Delegated Act, adjusted to the R&D focus:

• OpEx type A: expenditure related to assets or processes associated with Taxonomy-aligned activities;
• OpEx type B: expenditure that is part of a CapEx plan to expand aligned activities or bring eligible activities into alignment within a set timeframe;
• OpEx type C: under the current Annex I, point 1.1.3.2(c), expenditure relating to purchases of Taxonomy-aligned output and qualifying individual measures, including specified building-renovation measures, subject to the applicable 18-month implementation condition. The extent to which this route would be retained for an R&D-only KPI depends on the wording of the proposed amendment.

The existing materiality reliefs would stay as they are.

The boundary that matters for data is between capitalised and expensed R&D. ESMA describes the revised KPI as complementing the R&D expenditure already captured in CapEx, so on my reading development costs capitalised under IAS 38 keep flowing through the CapEx KPI and only the expensed share enters the new OpEx denominator. That puts a premium on R&D ledgers that already split the two.

The broader options failed on accounting anchors. Extending OpEx to all operating costs would have to lean on IFRS 18 Presentation and Disclosure in Financial Statements, whose first mandatory application only comes in 2027, and ESMA considers it too early to build on an “operating” category that is still untested in practice. A green-procurement definition raised new questions about which expenditure qualifies and how it links to financial reporting. Among the four approaches in the consultation, respondents gave the R&D option (approach D) the strongest support.

ESMA dropped the second half of its consultation proposal, the voluntary ‘OpEx+’ KPI. In its view, prescribed requirements for a voluntary metric may introduce excessive complexity and limit the flexibility that voluntary disclosure is generally intended to provide. What it asks for instead is a clear statement in the Disclosures Delegated Act on whether voluntary Taxonomy-related disclosures may sit inside the sustainability statement and how they relate to the ESRS, given that paragraph 106 of the revised ESRS excludes Article 8 disclosures from ESRS scope.

If the Commission allows such voluntary disclosures, ESMA proposes two safeguards: a separate reconciliation to the mandatory KPI with a component breakdown in line with point 1.2.3.3(a) and (b) of Annex I, and application of ESMA’s Guidelines on Alternative Performance Measures. ESMA notes that its Q&A on those Guidelines already applies them to Taxonomy-based alternative metrics. For how the APM Guidelines meet the new income statement, see our note on ESMA’s APM Guidelines and IFRS 18.

EU Green Bond issuers keep a wider definition. Article 4(1)(c) of the EU Green Bond Regulation (Regulation (EU) 2023/2631) permits the allocation of proceeds to qualifying operating expenditure under point 1.1.3.2 of Annex I to Delegated Regulation (EU) 2021/2178, provided that the expenditure was incurred no more than three years before issuance of the European Green Bond. ESMA recommends preserving a broader OpEx concept for this purpose. The three-year condition is set by Article 4(1)(c) of the Regulation itself and falls outside the Disclosures Delegated Act that ESMA’s advice would amend. Specifically, ESMA recommends keeping the current OpEx notion for use-of-proceeds purposes, minus the words “and any other direct expenditures”, and having the Disclosures Delegated Act list the cost items that count: non-capitalised R&D, building renovation measures, short-term leases, and maintenance and repair needed for the continued functioning of property, plant and equipment, whether carried out by the undertaking or by an outsourced third party.

The last element is a monitoring clause. ESMA asks the Commission, supported where relevant by the Platform on Sustainable Finance, to monitor OpEx, CapEx and Turnover reporting, and any voluntary reporting, for five years after the revised requirements enter into application.

Asset managers: no template rebuild and no OpEx blending

Under Article 3 and Annex III of Delegated Regulation (EU) 2021/2178, asset managers calculate their Taxonomy KPIs using the value of assets under management covered by the applicable methodology as the denominator (Annex III, section 1.2, refers to the AuM covered under Article 7(6)), rather than unrestricted total AuM. They disclose separate Turnover-based and CapEx-based measures. Annex IV distinguishes total AuM, assets covered by the KPI, and the corresponding Taxonomy-eligible and Taxonomy-aligned proportions. ESMA’s own consultation question noted that the current asset-manager template contains no OpEx element.

The consultation tested whether asset managers should be explicitly allowed to combine investees’ OpEx and CapEx KPIs on a voluntary basis. Twenty-one respondents answered, and 71% said no. In ESMA’s summary, respondents representing investors and asset managers opposed the idea unanimously, arguing that OpEx adds little decision-useful information and reflects a different economic concept from CapEx. The ESAs’ joint advice follows: do not introduce voluntary use of the OpEx KPI in financial undertakings’ Taxonomy disclosures, which within ESMA’s remit means asset managers’ disclosures. ESMA goes a step further and invites the Commission to consider keeping Turnover and CapEx as the key indicators for supervising and analysing financial products under the SFDR.

The cost-benefit annex puts the comparability problem in terms a fund reporting team will recognise: two asset managers holding the same assets could report different alignment figures simply because one used a blended methodology and the other did not.

On the template itself, ESMA advises the Commission to make no further changes to the asset-management annex at this point. The template was changed only recently through the Omnibus process, and ESMA agrees with a respondent’s warning that another change now would create a new reporting “vintage” and add burden in the short term. Once the SFDR review produces clarity, ESMA lists three reporting lines the Commission could consider removing:

• separate lines for investments in enabling and transitional activities;
• the split between exposures to non-financial and financial undertakings;
• lines for investments in Taxonomy-aligned nuclear and fossil gas activities.

The enabling and transitional rows (rows 13 and 12 in the numbering ESMA’s consultation question used) stay for now. The evidence behind that choice is thin. Fourteen respondents answered the question, and the report describes the result in two ways that do not match: paragraph 145 says most of them favoured keeping the rows, while paragraph 181 and the Annex I chart count eight against and six in favour. ESMA’s recommendation rests on the small, split sample and on the pending SFDR negotiations, where the Commission’s 20 November 2025 proposal would introduce ‘sustainable’, ‘transition’ and ‘ESG basics’ product categories. ESMA says it does not want its advice to pre-empt decisions on future product categories.

The asset-manager KPI never used investee OpEx, so the corporate OpEx redesign leaves its calculation untouched. Changes reach asset managers indirectly. CapEx Type C stays mandatory for investees, and ESMA explicitly weighed that financial undertakings currently rely on it. Mixed-group investees would publish a main-regime KPI in place of a weighted average, and ESMA says users relying on a single set of KPIs for a mixed group may use the main reporting regime KPIs. It also concedes that the consequences for SFDR uses of group-level KPIs are hard to assess while the SFDR itself is being revised.

Investment firms: the KPI changes sit in the EBA report

The Commission’s call gave the investment firms’ ‘other services’ KPI to the EBA, so ESMA’s report says nothing about how that KPI is computed. The EBA’s final report, submitted with a letter dated 28 October 2026, advises narrowing the KPI to four services that it links directly to capital markets and to the underlying asset:

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

The EBA also recommends that the Commission consider replacing the revenue-based KPI with one based on the value of assets under management, as part of a broader review that would also cover credit institutions’ off-balance sheet KPI and the KPI for asset managers. Its supervisory data, covering 141 investment firms at end-September 2025, put the annual gross revenue within the scope of the ‘other services’ KPI at EUR 7 billion, 90% of it from portfolio management.

Set the two reports side by side and a sequencing question appears. ESMA wants the asset-management annex left alone until the SFDR outcome is known, while the EBA invites a converged, asset-value methodology across the fiduciary KPIs, which would include that same asset-manager KPI. The positions can coexist if the Commission treats convergence as a later step. A group that reports both an investment-firm KPI and an asset-management KPI, for example because it holds a portfolio manager and a fund manager, has reason to read both reports before scoping any system change. That is my reading of the interaction; neither authority addresses it directly.

Scope will limit how many investment firms face any of this. The EBA expects only a small share of investment firms that are not credit institutions to fall within Taxonomy disclosure requirements, given their size and the CSRD perimeter. For those that do, the ESAs’ proposed group rules would apply as drafted: investment firms are one of the five “businesses” the Disclosures Delegated Act recognises, alongside non-financial undertakings, asset management, credit institutions, and insurance and reinsurance. The bank-side changes, including the EBA’s advice to drop two bank KPIs, are covered in our article on the EBA’s EU Taxonomy disclosures advice.

Group Taxonomy reporting: one main regime, secondary businesses above 10%

The ESAs advise removing the requirement to compute a weighted KPI that aggregates a group’s different businesses. ESMA’s case leans on research by the Commission’s Joint Research Centre: in its baseline scenario, 1,358 of 1,773 parent companies belong to mixed groups combining financial and non-financial activities, and the research notes that combining methodologies into a single weighted KPI can be misleading, while also cautioning that a parent-company-driven reporting mode alone is not a reliable proxy for the activities conducted across the entire group. The cost-benefit annex adds that the weighted figure can mix prudential and financial consolidation.

The replacement is a main reporting regime set by the parent undertaking:

• Default: the group discloses the KPIs for the parent’s type of business, following the Disclosures Delegated Act rules for that business.
• Financial conglomerate: where the group is identified as a financial conglomerate under Directive 2002/87/EC, the KPIs are those relevant to the entity leading the conglomerate under that Directive’s criteria.
• Financial holding parent, no conglomerate: the main disclosures follow the dedicated regulatory regime where one exists, for example the regime for financial holding companies as defined in Article 4(1), point (20), of Regulation (EU) No 575/2013 and subject to prudential regulation for credit institutions. Where no such regime applies, the group follows the non-financial undertakings’ regime.

The third limb deserves attention from asset-management groups. On my reading of the proposed wording, a group headed by a holding company that is neither a financial holding company under the CRR nor the head of a financial conglomerate would report the non-financial undertakings’ KPIs as its main regime, with its asset-management business moving into the secondary-business disclosures. ESMA’s executive summary describes the same outcome as applying the non-financial undertaking regime to other financial holdings.

Secondary businesses get their own disclosures where they fall outside the main regime, represent a significant share of the group’s business and do not exclusively serve the group’s internal needs. ESMA’s specific proposal gives “significant” a number: a 10% threshold applied to the consolidated turnover of the group’s secondary-business activities compared with group turnover, mirroring the threshold the Omnibus Delegated Act already applies to credit institutions’ other businesses. The test is cumulative, to prevent structuring. Two secondary businesses at 6% each total 12%, so neither can be dropped on the threshold alone.

Even above 10%, two situations allow omission. The first is where the main regime already captures the business with enough transparency, such as the asset-management business of a credit institution, or the financial activities of an automotive group that are covered by a Taxonomy activity. The second is where the business exclusively serves intragroup needs, as with captive insurance or reinsurance undertakings and other internal financial service providers inside groups led by non-financial undertakings. Where disclosure is due, ESMA recommends:

• consolidated disclosure for each secondary business, with the option to disaggregate further, for example by subsidiary;
• a dedicated simplified template in the revised Disclosures Delegated Act, so the figures sit alongside the other Taxonomy tables instead of inside a narrative;
• for non-financial secondary businesses, only the Turnover and CapEx eligibility and alignment KPIs;
• brief contextual information when secondary-business disclosures are omitted, plus narrative to reconcile the simplified templates with the consolidated financial statements where needed.

The threshold would run on consolidated figures already available internally for financial consolidation, so ESMA expects no new financial metrics to be needed. The Taxonomy assessment of the secondary subsidiaries is still work, which ESMA expects to benefit from the reliefs the Omnibus Delegated Act already introduced. It also asks the Commission to monitor the rule, if retained, to see how often groups arise whose secondary businesses are large and have a markedly different Taxonomy profile from the main regime.

Reliefs and a one-year phase-in, each with a disclosure attached

Topic 4 of the report adds optional reliefs modelled on the revised ESRS. ESMA stresses that the two frameworks differ, so it borrows the concepts and adapts them.

Acquisitions and disposals

ESMA advises a relief for acquisitions built on Sub-chapter 5.4 of the revised ESRS 1, and an adapted relief for disposals and divestments anchored on one principle: the KPI denominator follows the accounting treatment in the financial statements, as FAQ 17 of the second Commission Notice (C/2023/6747) already says. If the financial statements exclude a disposed business for the period, the Taxonomy KPIs exclude it too and no relief is needed. If they still include it, the denominator includes it and the undertaking may skip the eligibility and alignment assessment of the numerator, with an explanation in the contextual information.

For acquisitions the relief covers the numerator only. Respondents asked for the acquired business to come out of the denominator as well. ESMA did not take that up, reasoning that a KPI which deleted an acquisition’s effect from the denominator would not properly inform users about how the business has grown; contextual information can let users compute a denominator net of the acquisition instead.

Omission of protected information

A second relief would let undertakings omit information under the conditions in the last part of paragraph 3 of Articles 19a and 29a of the Accounting Directive, which the revised ESRS reproduces in Sub-chapter 7.7 of ESRS 1. The cases are, in exceptional cases, information whose disclosure would be seriously prejudicial to the undertaking’s commercial position; trade secrets as defined in Directive (EU) 2016/943; classified information under Regulation (EU) 2023/2418; and information protected under other Union or national law or to safeguard privacy or security. ESMA wants the ESRS 1 paragraph 101 safeguard carried over, so the undertaking must make every reasonable effort to keep the overall relevance of the disclosure intact.

Comparative information

Undertakings would be relieved from restating comparatives for year N where the methodology systematically relies on year N-1 data, but only in exceptional and duly justified circumstances. No comparatives would be required in the first year of Taxonomy reporting. Restatement would still be required where a KPI varies significantly in later periods.

Phase-in and eligibility-only reporting

Where the Commission amends the technical screening criteria for substantial contribution or do-no-significant-harm in the Climate or Environmental Delegated Acts, or changes the reporting requirements in the Disclosures Delegated Act, undertakings could elect to apply the amendments from the second financial year following their entry into force and keep the previous provisions for the year in between. ESMA wants this as a standard provision. Separately, an optional relief would let undertakings report eligibility only in the first financial year after new Taxonomy activities are introduced, or in their own first financial year subject to Taxonomy reporting, with alignment due from the following year. ESMA also advises aligning the application-date wording of the Disclosures Delegated Act with the ESRS by referring to the relevant financial year.

The common thread is a disclosure trail. Every relief and the phase-in are optional, and an undertaking using one would have to say so and explain why in the contextual information under Annex I. For an asset manager consuming investee data, that statement is the signal that an investee’s figure for the year rests on a relief. An investee using the eligibility-only relief, for instance, would publish no alignment figure for the activity concerned in that year. ESMA’s report does not address how financial undertakings should treat such gaps, so that point is my inference from the way the relief is drafted.

What ESMA declined to recommend

• A phase-in longer than one year, which ESMA says would undermine the credibility and timeliness of Taxonomy reporting.
• Grandfathering activities already assessed against existing criteria, which would split application of the criteria and reduce comparability.
• An undue cost or effort relief, which concerns the eligibility and alignment assessment and falls outside ESMA’s mandate; ESMA passes the idea to the Commission.
• A general materiality principle for Taxonomy reporting, which ESMA leaves to a wider future review that would also assess how the Omnibus thresholds have worked.

Template and contextual-information changes for listed issuers

The remaining recommendations are narrower, but they touch the tables and notes that issuers’ reporting teams complete every year.

• IFRS 8 Operating Segments: the Disclosures Delegated Act should state that IFRS 8 serves as contextual information and a consistency check in Taxonomy materiality assessments, without determining materiality. ESMA also asks for a more usable FAQ 7 in the Fourth Commission Notice, which deals with how IFRS 8 operating segments bear on the Taxonomy materiality assessment, and for illustrative examples at Level 3.
• Adjusted turnover KPI: the requirement in section 1.2.3.1 of Annex I to disclose an adjusted turnover KPI when sustainable bonds are issued would be removed. A suggestion to remove the adjusted CapEx KPI as well was not consulted on, so ESMA does not take it forward.
• Internal sales: disclosure of turnover generated from internal sales would become a voluntary KPI, provided where the undertaking considers it material and decision-useful.
• Contextual information: an optional general materiality filter would apply to the contextual information under Section 1.2.3 of Annex I. Materiality would be judged on quantitative and qualitative grounds, so small items that matter for strategy, transition plans or adaptation stay in.
• Digital tagging: the Commission should set a closed, clearly defined list of quantitative and qualitative contextual datapoints as the base for a future digital taxonomy. ESMA considers a numbers-only approach may be overly restrictive, because text-block tags let users find the narrative behind a metric.
• Cross-references: undertakings could cross-refer to ESRS disclosures and incorporate information by reference, on an optional basis and drawing on Chapter 9 of the revised ESRS adopted by Delegated Regulation (EU) 2026/1563. The revised standards are covered in our revised ESRS article.
• Adaptation: the clarification in FAQ 5 of the first Commission Notice (2022/C 385/01) would move into the Disclosures Delegated Act, with other FAQs considered case by case. ESMA also invites the Commission to consider measures to improve the FAQ process, citing consolidation into a single document, withdrawal of outdated guidance and clear marking of amendments as practical examples.
• Enabling and transitional activities: issuers’ separate reporting stays until the SFDR review is complete, for the same reasons as on the asset-manager side.

CapEx Type C is where ESMA moved furthest from its consultation. The consultation explored making Type C optional and respondents generally agreed, yet the final advice keeps it mandatory. ESMA’s reasons: Type C can carry material information on transition investment where an undertaking’s core activities sit outside the Taxonomy, financial undertakings rely on it, and an optional Type C would weaken the comparability of what ESMA calls one of the most relevant Taxonomy indicators. It asks the Commission instead to clarify “individual measures”, “purchase of output” and the boundary between CapEx Type A and Type C. A respondent example quoted in the report, from the French auditors’ body CNCC, shows the problem: a forest manager with Taxonomy-aligned turnover that buys electric vehicles from an aligned manufacturer could classify the spend as Type C purchase of output, as an individual measure, or as Type A because the asset supports its own aligned activity.

Frequently Asked Questions

Can we apply one of ESMA’s proposed reliefs early, for example to skip comparatives in our first Taxonomy year?

Not on the strength of the advice. The reliefs exist only as recommendations to the Commission. Until an amending act is adopted and applies, the Disclosures Delegated Act as amended by Delegated Regulation (EU) 2026/73, read with the Commission’s FAQs, sets what is required, and any departure needs a basis in that text.

Our fund manager sits in a group whose parent is an insurer. Which KPIs would the group publish under the ESAs’ approach?

The main regime follows the parent’s business, so the group would publish the insurance KPIs, unless it is identified as a financial conglomerate, in which case the KPIs of the entity leading the conglomerate apply. Asset management would then be a secondary business, disclosed through the simplified template if secondary businesses together reach the 10% turnover threshold and the asset-management business is neither already captured by the main templates nor exclusively intragroup. The insurer KPIs themselves are the subject of EIOPA’s separate advice, covered in our article on EIOPA’s underwriting KPI advice.

Does the 10% secondary-business test use prudential or accounting consolidation?

ESMA says the threshold should rely on consolidated figures available internally for financial consolidation purposes. The EBA’s report, on the other hand, says the current rules for credit institutions, which are based on the prudential scope of consolidation, should remain with clarification. For a bank-led mixed group the two bases could diverge, and neither report sets out how the Commission should reconcile them, so this remains an open drafting point for the amending act.

Our parent is a financial holding whose subsidiaries’ business models are independent of one another. Could the group stop publishing Taxonomy KPIs?

Possibly, but it is unsettled. Article 29a(7a) of the Accounting Directive, as amended by the Omnibus, gives such parents an option not to report consolidated sustainability information. ESMA understands that the option covers Taxonomy disclosures as well as ESRS disclosures, and asks the Commission to clarify the interplay with the Taxonomy Regulation, whose Article 1(2)(c) ties its obligations to Articles 19a and 29a. Until it does, the extent of the option for Taxonomy purposes is a question for legal review.

Would the one-year phase-in apply to the 2027 amendments themselves?

The report does not say. ESMA frames the phase-in as a standard provision for future amendments to the technical screening criteria or the Disclosures Delegated Act, and it does not state whether the amending act that introduces the provision should benefit from it. The answer will sit in the transitional and application articles of the Commission’s draft.

Are investment firms that are not banks likely to report the ‘other services’ KPI at all?

Few are, on the EBA’s assessment. Class 1 investment firms must apply for authorisation as credit institutions, and the EBA expects only a small share of the remaining investment firms, including Class 1 minus, Class 2 and Class 3 firms, to fall within the CSRD-based scope. The EBA adds that the KPI is also relevant for eligible standalone credit institutions and credit-institution-led groups that offer investment services.

Related Articles

• EU Taxonomy Disclosures: EBA Advises Dropping Two Bank KPIs: the EBA’s parallel advice on the Fees and Commissions and Trading Book KPIs, Green Asset Ratio templates and grandfathering.
• EU Taxonomy Underwriting KPI: EIOPA Narrows the Denominator: EIOPA’s advice on insurers’ underwriting KPI and its own take on group reporting.
• EU Taxonomy Disclosure Simplification: The 12 August ESMA Deadline: the consultation-stage proposals from ESMA, the EBA and EIOPA that this Final Report answers.
• Revised ESRS: The 60% Datapoint Cut Facing CSRD Reporters: the simplified sustainability reporting standards whose reliefs ESMA borrows for Taxonomy reporting.
• EU Green Bond External Reviewers: What ESMA’s Register Means for Issuers and Reporting Teams: issuer reporting under the EU Green Bond Regulation, where the wider OpEx definition would continue to apply.

Key Takeaways

• For FY2026, reporting entities should apply Delegated Regulation (EU) 2021/2178 as amended by Delegated Regulation (EU) 2026/73, together with relevant Commission guidance, subject to their reporting scope and available reliefs. In particular, Article 7(9) permits qualifying financial undertakings that make no relevant Taxonomy-alignment claims to use a specified management-report statement instead of the otherwise applicable KPI disclosures until 31 December 2027. The 2026 ESA advice is not itself an amending act.
• Listed issuers: the R&D-only OpEx KPI would need expensed R&D under IAS 38 tagged to OpEx types A, B and C, kept apart from development costs already in CapEx.
• Asset managers: no template rebuild is signalled. The enabling and transitional lines, the split between financial and non-financial investees and the nuclear and gas lines all remain until the Commission revisits them after the SFDR review.
• Investment firms: the four-service scope and the asset-value alternative come from the EBA’s report; ESMA’s advice reaches them through the group rules and the joint ESAs position against investee OpEx in financial KPIs.
• Mixed groups: the secondary-business test is cumulative across all secondary businesses, measured on group turnover, with exemptions only for businesses already captured or purely intragroup.
• Holding-company-led groups: the main-regime answer turns on financial holding company status under Article 4(1)(20) CRR and financial conglomerate identification, so confirm both before modelling the new templates.
• Every proposed relief and the one-year phase-in would leave a statement in the Annex I contextual information; teams that ingest investee Taxonomy figures can plan to capture that statement next to the KPI.

Sources and References

• ESMA, Final Report on Technical Advice on selected KPIs under the Taxonomy Disclosures Delegated Act, ESMA32-846262651-5927, 29 October 2026: ESMA (PDF)
• ESMA, “ESMA proposes simpler EU Taxonomy reporting”, press release, 29 October 2026: ESMA
• ESMA, Consultation Paper on Technical Advice on selected KPIs under the Taxonomy Disclosures Delegated Act, ESMA32-846262651-5826, 1 July 2026: ESMA (PDF) and consultation page
• European Commission (DG FISMA), Call for technical advice to the ESAs on certain Taxonomy KPIs and other aspects of the Disclosures Delegated Act, Ares(2026)2366154: EBA-hosted PDF
• European Commission, “Commission proposes to boost supplementary pensions and simplify rules on sustainable financial products”, news, 20 November 2025 (SFDR proposal with ‘sustainable’, ‘transition’ and ‘ESG basics’ product categories): European Commission
• EBA, Report on certain Taxonomy KPIs and other aspects of the Disclosures Delegated Act under Article 8 of the Taxonomy Regulation, EBA/REP/2026/19, October 2026: EBA (PDF)
• EBA Chair, letter to DG FISMA submitting the EBA Final Report on Taxonomy Disclosures, 28 October 2026: EBA (PDF)
• Regulation (EU) 2020/852 (Taxonomy Regulation), Articles 1(2) and 8: 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, 8.1.2026: EUR-Lex
• Malta Financial Services Authority, circular “Publication of the Amended Delegated Act of the EU Taxonomy Regulation in the EU Official Journal”, 13 January 2026: MFSA (PDF)
• Commission Notice C/2026/2558 (fourth notice) on the Disclosures Delegated Act as amended by the Omnibus Delegated Act, 30 April 2026: EUR-Lex
• Directive (EU) 2026/470 amending Directives 2006/43/EC, 2013/34/EU, (EU) 2022/2464 and (EU) 2024/1760 (Omnibus I), Articles 2 and 3: EUR-Lex
• Directive 2013/34/EU (Accounting Directive), Articles 19a and 29a: EUR-Lex
• Regulation (EU) 2023/2631 (EU Green Bond Regulation), Article 4: EUR-Lex
• Directive 2002/87/EC (Financial Conglomerates Directive): EUR-Lex
• Regulation (EU) No 575/2013 (CRR), Article 4(1), point (20): EUR-Lex
• Alessi, L. and Cotignano, G., EU Taxonomy Article 8 Review: Evidence on the OpEx KPI and group-level Taxonomy reporting, JRC148053, Publications Office of the European Union, 2026: data.europa.eu

Next checkpoint: the Commission’s draft amending act

With ESMA’s and the EBA’s final reports public, the next primary document is the Commission’s draft amendment to Delegated Regulation (EU) 2021/2178, targeted for adoption in Q1 2027. When it appears, compare three provisions against this report: the OpEx denominator wording (expensed R&D under IAS 38, or something wider), the group article (parent-led regime, the 10% cumulative threshold and the fallback for holding companies), and the transitional article that decides whether the one-year phase-in applies to the amendment itself.

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