DataSolmu blog
ESRS-40a For Non-EU Groups: Start With Supplier Data, Not The Final Report
Non-EU groups with significant EU activity can use the long runway to ESRS-40a to build dependable impact data now.
EFRAG has consulted on an exposure draft for ESRS-40a, a standard intended for third-country groups with significant activity in the EU under Article 40a of the Accounting Directive. The consultation closed at the end of October 2026, and EFRAG's technical advice is expected to go to the European Commission before the Commission runs its own process. On the current plan, the first reports would cover a financial year several years away.
That long runway is easy to read as a reason to wait. For exporters and their suppliers in countries such as Brazil or Türkiye, it is better read as time to build dependable data.
Understand What The Draft Focuses On
As presented by EFRAG, the exposure draft is narrower than the full ESRS for EU companies. It concentrates on impacts and leaves out several areas that full ESRS reporters address, and it asks stakeholders about options such as how widely impacts should be covered and how the standard relates to ISSB standards. Because the text is still a draft, teams should treat any detail as provisional and keep an eye on the final version.
Start Where The Data Actually Lives
Impact information for a non-EU group usually sits in operating sites and suppliers, not in head office. A practical early step is to list the sites and key suppliers connected to EU activity and to ask, for each one:
- which environmental and social impacts are plausibly relevant;
- what data already exists, for example energy, emissions or workforce records;
- who owns that data locally; and
- what evidence would support it later.
Groups that already collect supplier emissions data for CBAM can often reuse part of that work.
Keep Draft Assumptions Visible
Any preparation built on an exposure draft carries assumptions. Record which draft or presentation a decision was based on, so the team can revisit it when the final standard is adopted. This avoids the common problem of early work quietly hardening into requirements that were never confirmed.
Varmennappi helps groups collect and trace supplier evidence across sites and countries. It does not provide legal advice, auditor assurance, regulator acceptance or a guarantee of filing compliance. Each group remains responsible for confirming its own scope and obligations.
Practical Takeaway
Use the time before ESRS-40a applies to map EU-linked sites and suppliers, start collecting impact data with owners and evidence, and record which draft each assumption came from.