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ESRS-40a ED has been developed to implement the provisions of Directive 2013/34/EU of the European Parliament and of the Council (the Accounting Directive), as amended by Directive (EU) 2022/2464 (the CSRD) and Directive (EU) 2026/470 (the Omnibus I Directive). The Accounting Directive specifies the characteristics and content of the standardised Disclosure Requirements in ESRS-40a ED by distinguishing it from those applicable to large undertakings under ESRS. Notably, ESRS-40a ED content is aligned with revised ESRS (the European Commission adopted the Delegated Act on revised ESRS for EU undertakings on 3 July 2026), but it excludes reporting related to risks, opportunities, resilience and dependencies from the scope of ESRS-40a ED. Therefore, ESRS-40a ED focuses on impacts in line with Article 40a of the Accounting Directive.
The policy objectives of ESRS-40a reporting are to ensure a level playing field for companies operating in the EU market and to enhance the accountability and transparency of non-EU companies with significant business on the EU Single Market for their impacts on people and the environment.
ESRS-40a ED has the same structure as ESRS (12 standards) and the same articulation in the reporting areas (strategy; governance; impact management through policies and actions; metrics and targets). They have the same content as a starting point, with selected exclusions described in detail in this questionnaire. In particular:
a) disclosures on risks, opportunities, resilience and dependencies have been deleted as per Article 40a of the Accounting Directive, resulting in the deletion of certain datapoints and the amendment of other datapoints to reflect the target reporting objective;
b) other selected adjustments, such as the deletion of datapoints related to the EU taxonomy, which is not applicable to non-EU companies falling under the scope of Article 40a.
In addition, the following new elements have been included:
a) new paragraphs have been added to reflect important provisions in the Accounting Directive and to facilitate understandability;
b) option to limit disclosures for impacts other than climate to EU-related impacts only when certain conditions are met (‘mixed approach’) and consequential transparency;
c) transparency in the application of concepts and terms derived from EU laws and regulations to operations that are not in scope of those laws and regulations; and
d) flexibility in the application of incorporation by reference from reports issued in accordance with applicable laws or regulations, acknowledging that a substantial part of ESRS-40a disclosures (e.g. general disclosures and information about impacts) may be common with sustainability reports prepared in accordance with applicable jurisdictional sustainability reporting standards.
Regarding point (b), the European Commission (EC) requested EFRAG to explicitly consult on this option, which has been extensively discussed by EFRAG Sustainability Reporting Technical Expert Group (SR TEG) and the EFRAG Sustainability Reporting Board (SRB), and it has triggered a number of concerns described in the Basis for Conclusions, in the section dedicated to EFRAG SR TEG and the EFRAG SRB vote on the ESRS-40a ED.