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Sustainability reporting

ESRS-40a mixed approach: what EFRAG's outreach means for non-EU groups

EFRAG estimates that around 1,200 non-EU groups will be in scope of ESRS-40a from financial years starting in 2028. Right now, the mixed approach is one of the most debated parts of the draft. In September, EFRAG took the exposure draft on the road to outreach events in Mexico, the US, Brazil, New Zealand and Australia, and Canada. This article sets out what those sessions revealed about the mixed approach, where non-EU groups have concerns, and how they can prepare.

October 1, 2026

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