EFRAG publishes ESRS-40a exposure draft for non-EU groups with EU activities; begins 2028, reporting in 2029

ESRS-40a - EFRAG proposes standards for non-EU groups | PwC Switzerland

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ESRS-40a - EFRAG proposes standards for non-EU groups

On 23 July 2026, EFRAG published an exposure draft of the European Sustainability Reporting Standards for certain non-EU groups (draft ESRS-40a) for a 100-day public consultation. The standards would apply to non-EU groups with significant EU activities - and therefore also directly to a number of Swiss companies - beginning with financial year 2028 (reporting in 2029). The exposure draft is based on the revised European Sustainability Reporting Standards issued on 3 July 2026 (ESRS (2026)).

ESRS-40a would apply to non-EU groups (e.g. Swiss companies) that have an EU subsidiary or branch and meet specified turnover thresholds, with first reporting for financial years beginning on or after 1 January 2028.

Draft ESRS-40a reporting would focus on impact materiality, so sustainability-related risks and opportunities would not be required disclosures.

Draft ESRS-40a would allow reporting to be limited to EU-related impacts for topics other than climate change, if certain conditions are met.

In scope non-EU groups may apply either ESRS-40a or ESRS (2026) to comply with EU reporting requirements.

This publication summarises draft ESRS-40a and the key differences from ESRS (2026). It also details the topics addressed in the related public consultation. Comments on the exposure draft are due by 31 October 2026. The 100-day public consultation is also an opportunity for Swiss companies to provide feedback and help shape the future reporting framework before the 31 October 2026 deadline.

Partner, Leader Sustainability Assurance, PwC Switzerland

Director, Corporate Reporting Services, PwC Switzerland

+41 58 792 21 06

Senior Manager, Corporate Reporting Services, PwC Switzerland

+41 79 488 20 47

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