Beyond the GAAP no. 204 - 2025

This month, sustainability reporting has been the focus of much of the news. On 3 December 2025, after several months of intense work involving all stakeholders, EFRAG submitted its technical advice on the revised draft European Sustainability Reporting Standards (ESRS) to the European Commission (EC). The EC must now take this into account in order to produce a new delegated act on ESRS (’Set 2’), replacing the July 2023 act (’Set 1’), which remains applicable to wave 1 companies for the 2025 financial year.

On the European Taxonomy front, the rejection of a motion to object to the new Delegated Regulation on 3 December 2025 in the European Parliament makes it plausible that there will be no objection to this text by the scrutiny deadline (4 January 2026). However, its entry into force following publication in the Official Journal of the EU is expected to occur after its planned date of application (1 January 2026). In this context, the EC could make a public statement before then to confirm the possible application of this new Regulation by companies in their reporting published from 1 January 2026 onwards.