On October 29, 2026, the European Banking Authority (EBA) announced technical advice recommending targeted simplifications to EU Taxonomy disclosures for financial institutions.
The report examines KPI design, group reporting, grandfathering, and disclosure templates. Its recommendations aim to reduce complexity while preserving meaningful and comparable information.
This is technical advice to the European Commission—not an adopted amendment. The report does not, by itself, change reporting obligations.
Why Is the EBA Recommending Changes?
The report responds to the Commission’s request for advice supporting its review of the Article 8 Disclosures Delegated Act.
The EBA assesses whether particular indicators provide useful information relative to the effort required to calculate them. For some KPIs, it identifies significant operational challenges but limited value in explaining how financial institutions support environmentally sustainable activities.
The recommendations therefore address more than the number of disclosures. They consider whether calculation methods, reporting boundaries, and templates produce information that users can meaningfully compare.
1. Fees and Commissions and Trading Book KPIs: Removal Recommended
The EBA recommends removing both KPIs from Taxonomy disclosure requirements.
For the Fees and Commissions KPI, the report examines narrowing its scope to capital-market activities. However, it concludes that limited relevance and operational challenges still support removal. The Commission could consider a simpler alternative reflecting banks’ capital-market intermediation.
For the Trading Book KPI, the EBA explains that short-term trading positions may not meaningfully represent an institution’s longer-term sustainable-finance strategy. Institutions may also lack sufficient information or time to assess the Taxonomy alignment of underlying activities. A simpler measure focused on market-making is discussed as a possible alternative.
How Does This Relate to the Existing Postponement?
The report notes that Delegated Regulation (EU) 2026/73 has already postponed disclosure of these two KPIs to January 1, 2028.
The EBA’s recommendation goes further by advising their removal. It does not itself amend that timetable.
For reporting teams: Distinguish the existing postponement from the new recommendation. Neither should be interpreted as removing other applicable Taxonomy disclosures.
2. Investment Firms’ “Other Services” KPI: A Possible Measurement Change
The EBA recommends narrowing the KPI to services most relevant to capital markets.
It also recommends further consideration of an asset-value-based measure instead of a revenue-based measure, bringing it closer to indicators used for comparable asset-management activities.
Simplification could therefore involve more than deleting fields. A different measurement basis could affect data sources, calculations, and comparisons between reporting periods.
The report also advises the Commission to consider harmonizing disclosure requirements and templates across:
- Asset managers’ KPIs.
- Credit institutions’ off-balance-sheet assets-under-management KPIs.
- Investment firms’ “other services” KPI.
This would support more consistent reporting of similar activities conducted by different types of institutions.
For reporting teams: Identify how the data needed for an asset-value-based measure differs from revenue information currently used. Changes to reporting methods should follow adopted requirements, not the advice alone.
3. Grandfathering: Financial Instruments Need Different Treatment
Grandfathering concerns how financial instruments are treated when Taxonomy criteria subsequently change.
The report recommends distinguishing between:
- Instruments issued under the EU Green Bond Regulation: Grandfathering treatment should be aligned across the relevant regulations.
- Other financial instruments assessed at origination as financing Taxonomy-aligned activities: The EBA recommends unlimited grandfathering.
The report discusses use-of-proceeds loans and advances in this context.
For reporting teams: Retaining the origination assessment, applicable criteria, and evidence about the financed activity remains important. The recommendation should not be presented as one identical grandfathering rule for every financial exposure.
4. OpEx: Additional Data May Increase Complexity Without Sufficient Benefit
The European Supervisory Authorities recommend against introducing voluntary use of non-financial companies’ operating-expenditure KPI in financial undertakings’ Taxonomy KPIs.
Their reasoning includes limited additional usefulness, greater administrative complexity, and potentially reduced comparability.
For reporting teams: This recommendation concerns how financial institutions use counterparties’ OpEx information in their calculations. It does not recommend removing non-financial companies’ own OpEx disclosure requirements.
5. Group Reporting: Parent-Level KPIs With Additional Information Where Appropriate
The report recommends determining the main reporting approach primarily by reference to the parent undertaking, with specific treatment for financial conglomerates and holding-company structures.
However, parent-level indicators may not adequately explain groups with materially different secondary activities.
The EBA advises the Commission to consider identifying secondary KPIs where:
- Subsidiary activities differ from those of the parent.
- Their cumulative net turnover reaches at least 10% of group net turnover.
- Those activities are not already reflected sufficiently transparently in consolidated disclosures.
The report also considers whether activities exclusively serve the group’s internal needs. It advises against combining different financial and non-financial activities into a single weighted KPI.
For reporting teams: The 10% threshold is not a standalone trigger. Activity type, consolidation treatment, and information already disclosed also matter. These are recommended conditions—not newly binding requirements.
6. Disclosure Templates: Specific Adjustments Under Consideration
The EBA advises the Commission to consider several targeted changes for credit institutions, including:
- Removing Template 3—GAR stock and Template 4—GAR flow.
- Clarifying the placement of household and local-government exposures in Template 1.
- Reviewing the treatment of real estate financed outside the EU, with alternatives including exclusion or separate EU and non-EU asset information.
- Clarifying the asset scope in Template 2.
- Clarifying where nuclear and fossil-gas disclosures should appear.
Considering removal of Templates 3 and 4 is not the same as abolishing the Green Asset Ratio.
What Should Reporting Teams Review Now?
The report provides a basis for assessing potential reporting implications—not implementing unapproved changes.
Teams can map the recommendations to their existing processes:
| Review area | Information to document |
|---|---|
| KPI calculations | Current methodology, source data, and calculation owner |
| Group reporting | Parent classification, subsidiary activities, and consolidation boundaries |
| Financial instruments | Origination assessments and supporting Taxonomy-alignment evidence |
| Templates | Where information appears and which disclosures share underlying data |
| Governance | Responsibility for assessing developments and approving reporting changes |
This preparation can help teams assess the impact if the Commission subsequently adopts amendments.
How EcoActive Supports Connected Disclosure Management
The recommendations illustrate why reporting teams need to keep calculations, evidence, and disclosures connected—even when requirements are being simplified.
EcoActive ESG Reporting Software is an AI-native disclosure management platform that brings sustainability data, disclosures, supporting evidence, reviews, and approvals into a governed reporting process.
Native AI supports analysis and insights, while Agentic AI supports workflow actions and repeatable reporting activities. Regulatory interpretation, decisions about applicable requirements, and final approval remain under human control.
This connected approach supports traceability as teams assess recommendations and prepare disclosures under the requirements that apply to them.
Read the official EBA announcement and accompanying report.
Source: EBA Report on Taxonomy Disclosures (EBA/REP/2026/19)
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