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Standards and reporting

ESRS-40a

ESRS-40a is EFRAG’s draft standards work for the separate third-country reporting route, so current scope law and proposed reporting content must be kept apart.

What is ESRS-40a as at 26 October 2026?

It is an EFRAG exposure-draft process for certain non-EU undertakings rather than an adopted standard already determining the final reporting content EFRAG consultation launch Basis for Conclusions.

Separate law and draftRequirements and evidence

Module 01 / 03

Law

Identify the actual third-country reporting route.

Read the detailed guidance and evidence

Earlier labels included ESRS-TC and N-ESRS, while the owner now uses ESRS-40a EFRAG consultation launch.

The CSRD UK guide provides the broader UK-group context.

Which legal and standards records should remain separate?

A useful file distinguishes the reporting route, proposed content and any other reporting duties rather than using one label for all three.

Editorial law-status map rather than a legal determination.
RecordUseful distinctionReview question
Scope lawArticle 40a route as amended.Does the undertaking meet the relevant conditions?
Draft contentEFRAG exposure-draft documents.What remains proposed?
EU entity dutyAny separate Article 19a or 29a reporting.Is the subsidiary reporting on its own behalf?
Final contentFuture Commission process where relevant.Has an adopted instrument actually been identified?
Read the detailed guidance and evidence

The substantive Omnibus changes the route and its thresholds, while the exposure draft is a distinct standard-setting development Directive 2026/470, Article 2 point 13.

The CSRD thresholds guide handles the numerical decision record.

Why is a UK parent not automatically caught by EU sales?

The amended third-country route combines EU turnover in each of two years with a qualifying EU subsidiary or branch condition Article 2 point 13.

Check the whole routeRequirements and evidence

Module 01 / 03

Turnover

Use the relevant Union rather than worldwide measure.

Read the detailed guidance and evidence

A large headline revenue figure does not settle every limb of the route.

A branch route also has its own relationship to the qualifying-subsidiary condition.

The Omnibus change map separates the adopted scope changes from reporting-content revisions.

What does the fictional route file contain?

The invented Meridian Instruments group keeps an EU subsidiary’s own review separate from its third-country-parent review.

Original fictional record rather than a real-company scope conclusion.
RecordUseful distinctionReview question
Group mapThe parent and EU presence are described.Which route is being tested?
MeasurementsRelevant years and boundaries are retained.Are the figures comparable to the test?
Subsidiary fileIts own reporting position is reviewed.Has it been confused with the parent route?
Draft watchlistESRS-40a developments are labelled proposed.Is a draft being treated as final law?
Read the detailed guidance and evidence

Meridian is invented and no qualification or exemption is established.

The case illustrates why the project needs more than a statement that the group has European customers.

Does ESRS-40a use full double materiality?

The draft is impact-focused rather than importing the full ESRS financial-materiality lens Basis for Conclusions, BC15 Draft Log of Amendments.

Keep the perspectiveRequirements and evidence

Module 01 / 03

Impact

Identify the proposed reporting focus.

Read the detailed guidance and evidence

The impact-materiality guide explains the relevant assessment distinction.

Existing financial-risk information may inform context without replacing the required impact reasoning.

The draft remains a proposal, so the final adopted content must be checked when available.

What should a team know about the draft mixed approach?

The draft proposes a qualified approach for certain non-climate information rather than a blanket permission to report only EU activity Draft Log of Amendments Basis for Conclusions.

Editorial draft-reading questions rather than an instruction to apply an option.
RecordUseful distinctionReview question
ProposalIdentify the exact draft option considered.Which content does it concern?
BoundaryRetain why an EU-related distinction is meaningful.Can the boundary be explained?
LimitationRecord the conditions and uncertainty.Is a qualified proposal being overstated?
StatusKeep the source and date.Has the proposal changed?
Read the detailed guidance and evidence

The SRB Chair’s letter records reservations about the mixed approach, which reinforces the need to label the policy design as draft rather than settled reporting law Chair letter, 6 July 2026.

No vote count is needed to explain the reporting distinction.

Which dates belong in the planning file?

Separate consultation, technical advice, Commission adoption and the reporting application route rather than describing them as one deadline EFRAG consultation launch CSRD Article 5(2)(d).

Name each milestoneRequirements and evidence

Module 01 / 03

Consultation

The owner identifies the October 2026 endpoint.

Read the detailed guidance and evidence

The original CSRD supplies the separate third-country application route, while later amendments change scope Article 5(2)(d) Article 2 point 13.

The CSRD readiness guide can retain milestones without inventing a company’s final publication date.

Is ESRS-40a the revised 2026 ESRS package?

No: revised ESRS and the voluntary standard were adopted through separate instruments, while ESRS-40a remains a distinct draft process Regulation 2026/1563 Regulation 2026/1560 EFRAG launch.

A standards-status map rather than an equivalence statement.
RecordUseful distinctionReview question
Revised full ESRSPublished content for its applicable reporting route.Do not confuse it with draft 40a.
Voluntary standardA separate voluntary reporting basis and cap context.It is not the third-country-parent standard.
ESRS-40aDedicated draft work.Final content is not established by a different adopted act.
AnnouncementThe Commission’s July adoption release.Which instruments did the announcement describe?
Read the detailed guidance and evidence

The Commission’s July release concerns the revised and voluntary standards rather than completing the separate ESRS-40a process Commission adoption release.

What preparation is useful before final content is settled?

Build reusable evidence about the relevant activities and impacts while keeping proposed requirements and unresolved legal questions visible.

Prepare without overclaimingRequirements and evidence

Module 01 / 03

Context

Describe the group’s activities and relationships.

Read the detailed guidance and evidence

Meridian’s fictional team prepares an activity and impact-source map rather than claiming an exposure-draft checklist guarantees compliance.

The materiality template can provide an editable record, with the reporting perspective made explicit.

An internal readiness file should distinguish stable evidence work from assumptions that may need revision.

Can existing implementation guidance be applied unchanged?

EFRAG’s current implementation-guidance project identifies IG1–IG3 as support for the 2023 ESRS rather than final ESRS-40a guidance EFRAG guidance status.

Editorial source-control method rather than a new obligation.
RecordUseful distinctionReview question
Historical guidanceRecord its edition and non-authoritative role.What actually transfers?
Draft documentsRead their specific scope.Is an old reference being copied?
Company evidenceRetain original sources.Does the draft question need a different answer?
Final reviewReassess when the content changes.What remains conditional?
Read the detailed guidance and evidence

Do not turn a useful old example into an asserted requirement of a standard not yet adopted.

Keep the exact source and role beside each planning assumption.

What should advisers hand over now?

Request a dated route analysis, draft-status map and evidence plan rather than a promise that a final ESRS-40a report is already defined.

Buy a reviewable recordRequirements and evidence

Module 01 / 03

Route

Entity, group and relevant legal assumptions.

Read the detailed guidance and evidence

A CSRD consultancy engagement should specify which outputs are legal analysis, draft interpretation and data preparation.

The deliverable should remain editable so the team can update it after a verified change.

Preparation does not itself establish assurance or compliance.

What should software preserve?

A useful system retains the draft version and assumptions instead of silently updating a project to a new content set.

Editorial procurement tests without product claims.
RecordUseful distinctionReview question
VersionSource date and reporting basis.What was the plan built against?
MappingEvidence linked to proposed information.Which links need review after a change?
HistoryEarlier assumptions retained.Can a decision be reconstructed?
ExportEditable sources and open actions.Can the next reviewer continue?
Read the detailed guidance and evidence

Ask reporting software suppliers to demonstrate a source-version change and its effect on open tasks.

The standards homepage compares the wider reporting bases without treating them as interchangeable.

What should the group do next?

Confirm the route, retain the draft boundary and plan useful evidence work without calling the proposed content final.

Keep three filesRequirements and evidence

Module 01 / 03

Law

The applicable route analysis.

Read the detailed guidance and evidence

Meridian’s fictional review leaves a content-mapping question open rather than converting a consultation milestone into a completed reporting decision.

The value is a transparent plan that can be revised when the owner publishes the next verified stage.

How can a team plan for ESRS-40a?

This editorial nine-step workflow organises preparation without treating the draft as adopted law.

  1. 101

    Map the group

    Identify parent and relevant EU presence.
  2. 202

    Confirm the route

    Retain scope assumptions and evidence.
  3. 303

    Separate entity duties

    Keep EU entity and parent routes distinct.
  4. 404

    Record draft status

    Name the owner documents and date.
  5. 505

    Identify the perspective

    Keep impact focus explicit.
  6. 606

    Prepare context

    Map activities and source evidence.
  7. 707

    Track uncertainty

    Assign content-dependent decisions.
  8. 808

    Review owner updates

    Distinguish advice and adoption.
  9. 909

    Update the plan

    Retain reasons and revised mapping.

Frequently asked

Questions people ask

Is ESRS-40a already adopted law?

It remains an EFRAG exposure-draft process as at 26 October 2026.

Is ESRS-TC a different final standard?

It is an earlier label used before the owner adopted the ESRS-40a name.

Does any EU turnover trigger the route?

The amended route has specific consecutive-year turnover and qualifying EU-presence conditions.

Does the draft require full double materiality?

The draft is impact-focused rather than importing the full financial-materiality lens.

Does the revised full ESRS act finalise 40a?

The published revised ESRS instrument and the dedicated third-country draft are separate developments.

Can a draft checklist prove readiness?

It can organise preparation but cannot establish final content, reporting scope or compliance.

Sources

Primary sources

Primary provisions and official owner guidance checked on 26 October 2026; historical and draft resources are labelled in the guide.

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