On 3 July 2026, the European Commission submitted its draft Delegated Regulation (EU) 2026/5010 to the co-legislators, i.e. the European Council and the European Parliament. This regulation is expected to make the application of the new European Sustainability Reporting Standards (ESRS 2.0) mandatory from 2027 for companies and financial institutions within the scope of the Corporate Sustainability Reporting Directive (CSRD). Currently, within the scope of the CSRD, in simple terms, only companies with more than 1,000 employees and an annual net turnover exceeding €450 million are covered.kkk
Under ESRS 2.0, greenhouse gas (GHG) emissions financed through securitisations must also be disclosed. The Delegated Regulation (EU) 2026/5010 allows securitisations to be included – under certain conditions, but not automatically – in the sustainability statements of companies’ management reports.
Below, we outline key aspects of the “Omnibus legislation” and distinguish between the ESRS 2.0 requirements relevant to securitisations in corporate sustainability reporting and the purely supervisory disclosure obligations for financial institutions.
Current Disclosure Obligations for Securitisations in Climate Reporting
Beyond the ESG requirements under the Sustainable Finance Disclosure Regulation (SFDR), there have been few disclosure obligations specifically for securitisations in climate reporting to date. The current ESRS Set 1 on climate change (ESRS E1, particularly on financed emissions) has been mandatory under Delegated Regulation (EU) 2023/2772 since 1 January 2024 for companies subject to the CSRD in the EU. However, ESRS Set 1 does not explicitly address securitisations; instead, they may be considered part of the financed emissions that financial institutions are required to disclose.
The EBA Guidelines on ESG risk management for banks under CRD VI and the corresponding reporting under Pillar 3 of the Basel Framework reference ESRS Set 1 and use it as a key data source for supervisory ESG risk management. However, the application of these EBA Guidelines has been suspended for all financial institutions until the end of 2025 via a non-action letter from the EBA (see TSI kompakt from 6 August 2025). For smaller institutions and Small and Non-Complex Institutions (SNCI), the start of the EBA Guidelines and the associated Pillar 3 disclosures – including securitisations – has been postponed to January 2027. Larger institutions, however, already have the option – following the entry into force of Delegated Regulation (EU) 2026/5010 – to choose between ESRS Set 1 and ESRS 2.0 for the current financial year.
New Reporting Obligations: Asset Classes, Methods, and Data for Securitisation Transactions
The future disclosure of ESG data for securitisations in line with ESRS 2.0 will become mandatory and standardised under Delegated Regulation (EU) 2026/5010, with a focus on GHG emissions. The scope includes originators, sponsors, and investors subject to CSRD reporting requirements. Standardisation under ESRS 2.0 is achieved through the de facto adoption of the Partnership for Carbon Accounting Financials (PCAF) methodology.
The PCAF is a global coalition of around 50 financial institutions that have developed a standardised methodology for measuring and disclosing GHG emissions associated with financing. For securitisations, the PCAF methodology has been explicitly included since the December 2025 update of the PCAF Standard (Part A). The future ESRS E1 will require the most comprehensive quantification possible of Scope 1 to Scope 3 GHG emissions. Within the scope of ESRS E1, all securitisations of so-called “Hard Asset Receivables” – as defined by the PCAF – are covered, including:
- Residential and commercial real estate,
- Business loans & Corporate bonds,
- Auto loans & leases.
ESRS 2.0 demand transparency regarding the data and methods used. For securitisations, it must therefore be documented that the PCAF methodology has been applied – or explained if deviations occur.
Outlook
Delegated Regulation (EU) 2026/5010 and ESRS 2.0 were developed in the spirit of the Omnibus legislation to substantially reduce the administrative burden of ESG data requirements (see also TSI kompakt from 26 February 2025). However, the referenced PCAF methodology ensures that GHG emission data for securitisations will now also have to be disclosed in the sustainability statements of companies and financial institutions within the scope of the CSRD.
ESRS 2.0 do not replace existing ESG requirements, particularly those under the SFDR or the SECR, nor do they address their potential further integration into supervisory reporting requirements under Pillar 3 of the Basel Framework. Additionally, the transposition of the CSRD into German law is still pending (due in March 2027), which could potentially alter the scope of reporting entities (see above).
The draft Delegated Regulation (EU) 2026/5010 is subject to a scrutiny period by the Council and Parliament until 3 September 2026, which the co-legislators may extend by a further two months. We expect the regulation to be published in the Official Journal in Q4 2026, meaning ESRS 2.0 will become legally binding for securitisations from January 2027. The green omnibus is rolling – but instead of easing ESG requirements, it may impose additional burdens on parts of the securitisation industry..
Delegated Regulation (EU) 2026/5010 (Draft) on ESRS 2.0:
Delegated Regulation, Annexes