Japan's Financial Services Agency comments on EU's ESRS-40a Exposure Draft

Japan's Financial Services Agency submitted a comment letter on October 28, 2026, regarding the European Financial Reporting Advisory Group's ESRS-40a Exposure Draft published on July 23, 2026. The letter proposes clarifying disclosure requirements in ESRS-40a that are not covered by International Sustainability Standards Board (ISSB) standards, referred to as "top-ups." It also encourages EFRAG to incorporate an alternative approach that would reduce reporting burden on non-EU companies while requiring them to include all EU-related impacts in their reporting.