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Swiss Chinese Law Association — Geneva

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Legal Observatory / Sustainability and Responsibility

Legal Update European Union Regulatory guidance

EBA Advises European Commission on Targeted Simplifications for Taxonomy Disclosures

The European Banking Authority delivered technical advice to the European Commission proposing targeted simplifications to the Disclosures Delegated Act under Article 8 of the Taxonomy Regulation.

What Changed

  • Removal of the Fees and Commission’s KPI and Trading Book KPI from financial institutions' Taxonomy disclosure requirements.
  • Simplification and harmonization of asset management, investment firm, and Green Asset Ratio (GAR) disclosure templates.
  • Alignment of grandfathering rules limited strictly to bonds issued under the EU Green Bond Regulation.

Credit institutions, investment firms, and asset managers operating within the European Union face streamlined disclosure rules under new technical advice delivered by the European Banking Authority (EBA). Published in response to a March 2026 request from the European Commission, the EBA's advice supports the forthcoming review of the Disclosures Delegated Act under Article 8 of the Taxonomy Regulation and aligns with broader simplification efforts under the Omnibus Delegated Act.

The EBA's recommendations focus on reducing regulatory complexity and improving the usability of disclosed sustainability information while maintaining meaningful transparency. Key proposed modifications focus on five core areas:

- Removing the Fees and Commission’s Key Performance Indicator (KPI) and the Trading Book KPI from Taxonomy disclosure obligations;

- Simplifying the 'other services' KPI for investment firms, including services related to capital markets;

- Aligning grandfathering provisions exclusively with the EU Green Bond Regulation for bonds issued under that specific framework;

- Excluding the operational expenditure KPI disclosed by non-financial undertakings from the calculation of financial undertakings' KPIs; and

- Streamlining group disclosures by utilizing the parent undertaking’s KPIs, complemented where relevant by KPIs for material secondary activities without further aggregation.

Additionally, the EBA advises targeted template improvements. These measures aim to simplify and harmonize disclosure templates across credit institutions' asset management activities, asset managers' activities, and investment firms' activities. The advice also recommends clarifying and simplifying the Green Asset Ratio (GAR) templates applicable to credit institutions.

Developed in cooperation with the European Securities and Markets Authority (ESMA) and the European Insurance and Occupational Pensions Authority (EIOPA), the advice incorporates feedback from a public consultation. Issued pursuant to Article 16a(4) of Regulation (EU) No 1093/2010, this advice forms part of the EBA’s 'Simplifying to strengthen' campaign and aligns with recommendations from the EBA Task Force on Efficiency (TFE).

While the publication date of the press release and entry-into-force dates for legislative changes are not provided in the source material, the advice sets the direction for future Commission rulemaking. Financial entities subject to EU Taxonomy reporting should monitor subsequent legislative developments from the European Commission.

Who May Be Affected

Credit institutions, investment firms, asset managers, and financial undertakings subject to EU Taxonomy disclosure requirements.

Cross-Border Context

Financial entities outside the EU that operate subsidiaries, provide services, or issue debt instruments within the EU market under the EU Taxonomy framework are directly impacted by changed reporting templates and KPI obligations.

What to check next

  • European Commission's forthcoming draft review of the Disclosures Delegated Act under Article 8 of the Taxonomy Regulation.
  • Implementation progress of the broader simplification initiatives under the Omnibus Delegated Act.

This article provides general information and does not constitute legal advice. Consult the official text and obtain advice appropriate to your circumstances where needed.

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