EU Taxonomy Disclosures Review: What the Platform's Two-Tier OpEx KPI Proposal Means for CSRD Reporters

Why this matters now

If you report under the CSRD, your EU Taxonomy KPIs sit inside your sustainability statement, so every change to the Taxonomy Disclosures Delegated Act ends up in your reporting process. In September 2026 the EU Platform on Sustainable Finance responded to the Commission's review of that Delegated Act. Its recommendations are not law. They are, however, a good indicator of where the Commission may land, and they affect how you design your data pipeline for FY2026 and FY2027.

This post covers what the Platform recommended, what is still undecided, and a short action list. It deliberately does not repeat the earlier guidance on the new Taxonomy templates and the 10% materiality threshold; read that first if you need the baseline.

What the Platform recommended

According to the Linklaters October 2026 ESG newsletter, the Platform's response includes four points that matter for preparers:

1. A two-tier OpEx KPI approach. Instead of one operating expenditure KPI computed on a single denominator, the Platform recommends a two-tier structure for OpEx.
2. Removing the weighted-average consolidated KPI for group reporting. Groups would no longer have to publish a weighted average across business lines as a consolidated KPI.
3. Clarifications on climate change adaptation in the Delegated Act, where preparers have struggled to apply the criteria consistently.
4. Keeping the mandatory CapEx type C KPI, but with clearer guidance on how plan-based CapEx should be identified and disclosed.

The newsletter does not set out the detailed mechanics of the two tiers, so treat any specific numerator or denominator design you read elsewhere as speculation until the Commission publishes a draft.

What is not decided

• The Commission has not adopted any of these recommendations. A Platform response feeds into a review; it does not amend the Delegated Act.
• Timing of any amendment is open. Revised ESRS were published in the Official Journal on 24 September 2026 and apply to financial years beginning on or after 1 January 2027, with FY2026 reporters able to choose existing ESRS, existing ESRS with reliefs, or the revised set. Taxonomy changes may not move in lockstep with that timeline.
• The scope question is separate. Whether you report Taxonomy KPIs at all depends on whether you remain in CSRD scope after the Omnibus (more than 1,000 employees and more than EUR 450 million net turnover).

A note on the courts

On 30 September 2026 the EU General Court largely upheld the Taxonomy technical screening criteria for aviation and shipping, with one exception: for gas-fuelled vessels, the criteria must set emissions thresholds or cross-refer to an identifiable standard such as FuelEU Maritime. If you operate in transport, this keeps the current criteria in place for now while pointing to a future fix for gas-fuelled shipping.

What to do now

• Keep OpEx at activity level. Whatever tier structure emerges, data tagged to activities and cost categories will adapt more easily than a single consolidated number.
• Do not hard-wire the weighted-average group KPI. Keep entity- or segment-level KPIs available so you can drop or rebuild the consolidated figure.
• Document your CapEx type C plans. If the CapEx type C KPI stays mandatory with clearer guidance, plan approval, timing and budget evidence will be what assurance providers ask for.
• Review adaptation assessments. If you rely on judgement calls for adaptation criteria, record the reasoning now so you can re-test it against any clarified wording.
• Watch for the Commission's draft. Until then, apply the current Delegated Act as written.

Bottom line

The Platform's direction is toward simpler group-level reporting and clearer rules, not fewer obligations for in-scope companies. Build for flexibility, apply today's rules, and revisit once the Commission publishes a draft.

Sources: Linklaters, ESG newsletter October 2026.