ESMA Launches Consultation Paper on selected KPIs under the Delegated Act under the Taxonomy Regulation
Published 10 July 2026
Category: Impact and ESG
The Commission’s Delegated Regulation (EU) 2026/73 of 4 July 2025 (the “Delegated Act”) entered into force on 1 January 2026 and introduced an initial round of targeted simplifications to the Taxonomy reporting framework. Please refer to our previous Pulse update.
Following this, the Directorate-General for Financial Stability, Financial Services and Capital Markets Union (DG FISMA) requested the European Supervisory Authorities (“ESAs”) to provide technical advice to support a further review of the Delegated Act under the Taxonomy Regulation. Each ESA was asked to examine specific topics within its own remit, alongside a number of horizontal issues of common relevance.
On 1 July 2026, ESMA opened a public consultation on selected KPIs under the Taxonomy disclosure framework. The consultation primarily focuses on the following three main topics:
- Revision of the OpEx KPI: ESMA sets out a range of options to revise KPI from minor adjustments to more fundamental changes. ESMA’s preferred position is to limit the mandatory OpEx KPI to R&D expenditure, which would give the KPI a clearer purpose and reduce complexity. Companies would additionally have the option to voluntarily disclose a broader “OpEx+” KPI covering other operating expenditures, such as green procurement, that are material to their activities.
- Voluntary use of OpEx KPI by financial undertakings (horizontal issue): The consultation also examines whether and how OpEx information reported by non-financial undertakings could be useful to financial undertakings, particularly asset managers. The ESAs note that the value of such information to financial undertakings depends on how the KPI is ultimately revised, and that a voluntary reporting option risks introducing additional complexity without delivering significantly more useful information in return.
- Group Taxonomy reporting (horizontal issue): The consultation also identifies challenges in the current framework for mixed groups and financial conglomerates, notably the insufficient relevance and potential methodological errors of aggregated KPIs. ESAs’ preferred approach is to require groups to report KPIs aligned with the type of activity conducted by the parent undertaking with subsidiaries only required to report additional KPIs where their business differs materially from that of the parent.
Next steps
The consultation period runs until 12 August 2026, in parallel to the consultations by the other ESAs. ESMA will host a public hearing on 22 July 2026 to present its proposals and gather stakeholder input. Following the consultation, ESMA aims to deliver its final technical advice to the European Commission by the end of October 2026.
ESMA’s consultation paper is available here.
Tags: ComplianceCSRDDisclosure RequirementsESRSSFDRSustainability
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