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The European Commission has announced a delay and consolidation of the European disclosure regulation, aiming to streamline the application of requirements for companies and reduce administrative burdens. The new timetable, updated by BaFin, moves the binding date from January 1, 2022, to July 1, 2022.
The consolidation of 13 technical regulatory standards into a single delegated act is part of a broader effort to make sustainability reporting standards clearer and more manageable. This move is expected to help companies, particularly large public interest entities already subject to reporting duties under the Corporate Sustainability Reporting Directive (CSRD), avoid premature or overly complex requirements.
The delay and consolidation reflect a pragmatic approach that balances regulatory ambitions with practical implementation readiness across EU companies transitioning to new sustainability reporting frameworks. Key reasons include the reduction of complexity and administrative burden, extended phase-in and reporting relief for early reporters, maintaining EU competitiveness, and ongoing legislative scrutiny and stakeholder consultation.
The Commission's aim is to enable product manufacturers, financial advisors, and financial supervisors to implement the detailed rules smoothly. To achieve this, the Commission intends to bundle all drafts and send them as a single legislative package. The implementation drafts from the ESAs were long and contained many technical details.
The European disclosure regulation, which came into force on March 10, 2021, obliges market participants to make their sustainability actions transparent. Financial asset intermediaries who are active under Section 34f of the German Trade Regulation Act do not currently have to disclose their sustainability efforts, but intermediary associations AfW and Votum recommend implementing the rules in their businesses.
However, many questions regarding the disclosure regulation remain open, such as when a financial product is considered truly sustainable, and what non-sustainable share a portfolio can contain to still be considered sustainable. The affected market participants will have six additional months to prepare for the detailed regulations, with the new start date being July 1st, 2022.
BaFin has announced that it will only base its supervisory activities on the regulation text itself until the detailed regulations become binding. The Commission presented this plan in a letter to the three supervisory authorities EBA, ESMA, and EIOPA. The ESAs sent joint proposals for some technical regulatory standards to the EU Commission on February 4th.
Sustainability is a central topic that could also affect the intermediary segment in the future. The Commission's "quick fix" amendments, adopted in 2025, extend phase-in reliefs and allow some companies (especially “Wave 1” reporters) to omit certain challenging disclosures temporarily, helping them improve reporting quality without undue pressure.
The new start date for the detailed rules in the legislative package is July 1st, 2022. This delay and consolidation are expected to provide a more practical and manageable approach to sustainability reporting for various market participants across the EU.
Other market participants, particularly large public interest entities, can now avoid premature and overly complex requirements with the delayed start date for the detailed regulations in the legislative package, which is on July 1st, 2022. This delay and consolidation, part of the European disclosure regulation, will help various businesses across the EU implement the detailed rules smoothly in their finance operations.
