EBA Taxonomy advice reflects key ABBL priorities on simpler disclosures

The ABBL has consistently called for EU Taxonomy disclosure requirements that are proportionate, workable in practice and focused on decision-useful information. This is also reflected in the association’s broader position on the EU Taxonomy, which advocates fewer indicators, less duplication and greater proportionality in sustainability reporting.

In its response to the EBA’s consultation on the Taxonomy Disclosures Delegated Act, the ABBL made a number of targeted recommendations aimed at reducing unnecessary complexity while preserving the usefulness of the framework.

The EBA’s final advice, published on 29 October 2026 following its submission to the European Commission, reflects several of these priorities.

Two additional KPIs recommended for removal

The clearest outcome concerns the Fees and Commissions KPI and the Trading Book KPI.

The ABBL argued that both indicators were costly and complex to implement while providing limited insight into banks’ contribution to financing Taxonomy-aligned activities.

The EBA has now recommended removing both KPIs, even after considering narrower versions.

This directly reflects the ABBL’s call to eliminate them rather than devote resources to refining disclosures with limited practical value.

A more targeted “other services” KPI

The ABBL’s advocacy is also reflected in the recommendation to limit investment firms’ “other services” KPI to capital-markets activities.

The ABBL argued that the KPI should cover only services with a clear and direct connection to capital markets, excluding the execution of orders and the reception and transmission of orders.

The EBA’s advice moves in the same direction by recommending a simplification of the KPI around services related to capital markets.

The EBA’s covering communication does not, however, specify the detailed list of services proposed by the ABBL.

Simpler group-level reporting

Another important area of alignment concerns group-level reporting.

The European Supervisory Authorities recommend relying on the parent undertaking’s KPIs, complemented, where relevant and subject to defined conditions, by KPIs for material secondary activities, without further aggregation.

This closely matches the ABBL’s position that subsidiary-level disclosures should be required only where activities are material and are not already reflected in group reporting.

The approach would reduce duplication while preserving visibility on material activities within diversified groups.

OpEx kept outside financial institutions’ KPI methodology

The advice also reflects the ABBL’s core position that operational expenditure, or OpEx, should not be incorporated into financial institutions’ KPI methodology.

The ABBL supported excluding OpEx from mandatory reporting while allowing voluntary use where the information was reliable and useful.

The ESAs go further by advising against voluntary inclusion as well.

The underlying principle nevertheless remains aligned with the ABBL’s position: adding OpEx to financial institutions’ Taxonomy KPIs would increase complexity without necessarily improving the usefulness of the disclosures.