Preparing upcoming sustainability statements: the AMF draws listed companies’ attention to ESMA’s 2026 recommendations
AI Analysis
On 14 October 2026, the AMF highlighted ESMA’s 2026 European Common Enforcement Priorities for sustainability statements in issuers’ 2026 annual financial reports. The publication does not introduce a new binding reporting rule, but it signals that French and other EEA national enforcers will scrutinise double-materiality assessments, connectivity between impacts, risks and opportunities (IROs) and policies, actions and targets (PATs), and consistency of ESRS E1 and S1 disclosures during a transitional year for the reporting standards.
Key dates
- 2026-07-03
- The European Commission adopted the revised and simplified ESRS and the related Delegated Regulation containing the transitional options and Article 2(1)(b) reliefs.
- 2026-09-21
- The revised and simplified ESRS were published in the Official Journal of the European Union.
- 2026-10-13
- ESMA published the 2026 European Common Enforcement Priorities for corporate reporting, including priorities for sustainability statements.
- 2026-10-14
- The AMF drew French listed companies’ attention to ESMA’s 2026 sustainability-reporting priorities.
- 2026-11-04
- The AMF is scheduled to hold an educational webinar on lessons from its review of 2025 sustainability statements.
- 2027-01-01 Deadline
- Issuers preparing sustainability statements for financial year 2027 should be prepared to use the revised ESRS and generally omit non-material information except where expressly required.
Suggested considerations
- Compliance teams may wish to document the decision to use ESRS Set 2, Set 1, or Set 1 with the Article 2(1)(b) reliefs, and include a clear statement of the selected basis in the 2026 sustainability statement.
- Companies should consider refreshing their double-materiality assessment files to evidence methodology, thresholds, data sources, stakeholder and value-chain coverage, and equivalent treatment of positive and negative impacts.
- Reporting owners may wish to create an IRO-to-PAT-to-metric mapping that identifies the topics and scopes covered, any material IROs without corresponding policies, actions or targets, and the reasons for partial coverage.
- Climate reporting teams should reconcile the organisational and operational scope of the GHG inventory with emissions-reduction targets, quantify targets in absolute terms where applicable, explain any science-based or 1.5°C alignment claim, and distinguish gross from net targets.
- Human-resources and sustainability teams should link workforce actions, such as training, to policy objectives and measurable outcomes, including discrimination-prevention objectives under ESRS S1.
- Finance, risk and sustainability functions should perform a consistency review across the sustainability statement, financial statements, risk factors, management commentary, executive summary, prior-year disclosures and other public communications.
- Companies should assess the likelihood of missing 2030 targets, document remediation or contingency plans, and disclose relevant risks where target achievement is uncertain.
- Reporting teams may wish to preserve an audit-ready evidence trail for targets, methodologies, baseline years, restatements, scope changes, financial resources and comparative information.
What changed
For financial year 2026, issuers may use the revised and simplified ESRS Set 2 adopted by the European Commission on 3 July 2026 and published in the Official Journal on 21 September 2026, the current Set 1 including the July 2025 quick-fix simplifications, or Set 1 together with the specific reliefs listed in Article 2(1)(b) of the Commission Delegated Regulation of 3 July 2026. ESMA expects issuers to identify transparently which option they have used. The 2026 enforcement focus continues the 2024 and 2025 focus on double materiality, requiring comparable rigour for positive and negative impacts, clear disclosure of assessment methods and thresholds, and coverage of own operations and the value chain. Issuers are also expected to connect material IROs with relevant policies, actions, tar
Compliance impact
The impact is significant for in-scope listed issuers because the ECEP guides the selection and conduct of national enforcement reviews, even though the AMF notice itself is guidance rather than a new binding obligation. Weak evidence for double materiality, disconnected IRO/PAT disclosures, inconsistent climate data or unsupported targets may increase the risk of regulator challenge, required cor
Who is affected
Related regulations
References
AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.
What the AMF said
Periodic & ongoing disclosures Sustainable Finance Preparing upcoming sustainability statements: the AMF draws listed companies’ attention to ESMA’s 2026 recommendations
Published by AMF . Read the full notice at the source for the authoritative text.