EFRAG Launches Public Consultation on Exposure Draft for ESRS-40a
July 23, 2026
On July 23, 2026, EFRAG published for public consultation an exposure draft, European ESRS for
Certain Non-EU Undertakings in Accordance With Article 40a of the Accounting
Directive (ESRS-40a1). ESRS-40a apply to certain non–European Union (E.U.) undertakings within the
scope of the Corporate Sustainability Reporting Directive under Article 40(a)2 of the Accounting Directive3 (sometimes referred to as “enterprise-level” reporting). The ESRS-40a are
generally based on the full 2026 revised ESRSs,4 with certain additions and deletions. Notably, the ESRS-40a focus on impacts
only rather than a combination of impacts, risks, opportunities, resilience, and
dependencies.
In addition to focusing on impacts only, the public consultation seeks stakeholder
feedback on references to E.U. legislation, an optional mixed reporting approach to
limiting the reporting to EU-related impacts only, and interoperability.
Interested parties may access consultation materials and submission instructions on
EFRAG’s official Web site. Feedback on the consultation is
due by October 31, 2026.
Footnotes
1
EFRAG previously referred to ESRS-40a as non-EU ESRS (N-ESRS) or ESRS for
Third-Country Undertakings (ESRS-TC).
2
Non-E.U. entities that meet both of the following criteria are within the
scope of Article 40a: (1) exceeding €450 million net turnover in the E.U. at
the group level for each of the last two consecutive financial years and (2)
having at least one E.U. subsidiary or branch with more than €200 million in
net turnover in the preceding financial year.
3
Directive 2013/34/EU of the European Parliament and of the European
Council.
4
Revised ESRSs were adopted as a delegated act on July 3, 2026, and are
subject to a scrutiny period before entering into force.