The EBA advises on targeted simplifications to Taxonomy disclosures

Key dates

2026-03-04

The European Commission requested technical advice from the ESAs on the review of Article 8 Taxonomy disclosures.

2026-10-29

The EBA published its final technical advice and submitted its report to the European Commission.

Suggested considerations

• Compliance teams should treat the publication as forward-looking technical advice and should not cease reporting the Fees and Commissions KPI, Trading Book KPI or other existing disclosures unless and until the Commission adopts applicable amendments or transitional measures.
• Firms should map current Taxonomy data lineage, controls, templates and calculation logic against each proposed change so that implementation can be accelerated if the Commission follows the EBA advice.
• Banking groups should assess how parent-level KPIs and material secondary-activity KPIs could affect consolidation methodologies, entity-level data ownership and audit trails.
• Investment firms should inventory fees, commissions and other services currently included in the relevant KPIs, particularly capital-markets-related services, and model the effect of the proposed narrower approach.
• Credit institutions should review Green Asset Ratio template production and identify duplicated or low-value data points that may be removed or harmonised in a future delegated act.
• Firms should monitor the Commission’s review of Commission Delegated Regulation (EU) 2021/2178, the related Omnibus simplification measures and any final ESA or Commission guidance before updating policies, public disclosures or regulatory reporting systems.
• Legal and regulatory-change teams may wish to engage with the Commission consultation or legislative process and preserve evidence supporting current reporting interpretations during the transition.

What changed

The EBA recommends removing the Fees and Commissions KPI and the Trading Book KPI from Taxonomy disclosure requirements. It proposes simplifying the investment firms’ other-services KPI, including capital-markets-related services, and aligning grandfathering provisions with Regulation (EU) 2023/2631 on European Green Bonds, but only for bonds issued under that Regulation. The EBA advises against introducing the operational expenditure KPI of non-financial undertakings into financial undertakings’ KPI calculations. For groups, it proposes using the parent undertaking’s KPIs and, where defined conditions are met, adding KPIs for material secondary activities without further aggregation. It also recommends simplified and harmonised templates for credit institutions’ asset-management activitie

Who is affected

• EU-authorised credit institutions subject to Article 8 Taxonomy disclosures
• EU-authorised investment firms subject to Article 8 Taxonomy disclosures
• EU parent undertakings and financial groups preparing consolidated Taxonomy disclosures
• Asset managers and investment firms preparing the relevant Taxonomy disclosure templates
• Non-financial undertakings whose KPIs may be used as inputs to financial undertakings’ Taxonomy calculations
• Investors and counterparties relying on Taxonomy KPIs and Green Asset Ratio information

Related regulations

• Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment, particularly Article 8
• Commission Delegated Regulation (EU) 2021/2178 supplementing Regulation (EU) 2020/852 on the content and presentation of Taxonomy disclosures
• Regulation (EU) 2023/2631 on European Green Bonds and optional disclosures for bonds marketed as environmentally sustainable and sustainability-linked bonds
• Regulation (EU) No 1093/2010 establishing the European Banking Authority, particularly Article 16a(4)
• MiFID II
• Capital Requirements Regulation