Corporate Disclosure

Governed by the integration rule document. Scope: CSRD, ESRS, ESRS-40a, the Voluntary Standard and disclosure-side digital reporting.

2026-W38 authority register

ID	Finding	Authority / disposition
CD-01	Commission adopted revised ESRS and the separate Voluntary Standard on 3 July 2026; the Commission register still describes both as not in force until OJ publication.	LEGAL_ACT, ADOPTED_PENDING_OJ; AWAIT_AUTHORITY for Runtime activation.
CD-02	Parliament recorded non-objection to C(2026)05010 on 11 September 2026.	LEGAL_ACT procedure event, SCRUTINY_CLEARED_PENDING_OJ; Parliament event does not by itself prove OJ publication or separate Voluntary Standard activation.
CD-03	EFRAG's draft revised-ESRS datapoint list is non-authoritative supporting material with 2023/IG3 mappings; fatal-flaw review closes 23 October.	TECHNICAL_RESOURCE; AWAIT_TECHNICAL_SPEC for final migration resource.
CD-04	Directive (EU) 2026/470 protects value-chain undertakings with no more than 1,000 employees from information demands exceeding the voluntary standard and permits reliance on size self-declaration unless manifestly incorrect.	LEGAL_ACT, verified at Article 29ca; architecture consequence is a request-entitlement policy, not a new questionnaire system.
CD-05	ESRS-40a remains an exposure draft; consultation closes 31 October 2026 and EFRAG expects technical advice in January 2027.	PROPOSAL; AWAIT_AUTHORITY.

Architecture Integration decision

Revised ESRS: stage through existing Pergamum Pulse authority and XBRL activation contracts

Canonical review found that Pergamum Pulse already separates registered technical artefacts, release, Runtime activation, legal authority, semantic-mapping authority and filing authority. The revised ESRS therefore do not justify a new WSI-specific activation mechanism.

Required integration behavior:

1. capture the Commission act, Parliament scrutiny event, eventual Council/OJ evidence and applicability dates as separate authority facts;
2. keep revised ESRS and the Voluntary Standard as separate regulatory objects with separate activation gates;
3. stage revised datapoint mappings without overwriting 2023 ESRS concepts or historical reports;
4. bind a reporting profile only when the applicable legal version and reporting period resolve successfully;
5. preserve early-application eligibility as a separate applicability decision rather than a global active flag.

Disposition: generic activation architecture NO_ACTION; revised-ESRS profile/migration PROPOSED_DELTA; legal activation AWAIT_AUTHORITY.

Supplier request ceiling: compose with EPU Supplier Contributions

The existing EPU Supplier Contribution Architecture already implements:

Resolve → anticipate → acquire the delta → validate → reuse.

It also implements No Ask Before Reuse and requirement-driven minimum unresolved questions. The CSRD development therefore strengthens an existing architectural direction rather than requiring a separate FOGE supplier-questionnaire subsystem.

The genuine delta is a request-entitlement policy evaluated before a contribution request is issued. It should resolve:

• legal basis and regulatory profile;
• requester context;
• protected-undertaking status;
• employee-count evidence and reference period;
• self-declaration provenance;
• manifest-error state;
• applicable request ceiling profile;
• existing reusable evidence;
• unresolved evidence gap;
• permitted question/data scope;
• decision receipt and reason.

This policy must remain separate from CSDDD's different partner safeguard.

Disposition: FORM_CHANGE, REQUEST_RIGHTS_DELTA, WORKFLOW_CHANGE; PROPOSED_DELTA. This is part of unregistered candidate: regulatory request-entitlement gate rather than a new contribution architecture.

ESRS concept migration

The draft EFRAG mapping should populate a candidate relationship layer, not replace canonical identities. Relationship types should include unchanged, renamed, modified, split, merged, deleted, new and semantic-scope-changed, with source/target versions, authority and review state.

Canonical concept identity must remain distinct from ESRS paragraph/datapoint identity and from XBRL taxonomy identity.

Disposition: TAXONOMY_CHANGE, INTEROPERABILITY_DELTA; AWAIT_TECHNICAL_SPEC before final mapping activation.

ESRS-40a

Maintain a distinct candidate reporting profile and reporting perimeter. Do not implement the exposure draft as normal ESRS minus fields. Draft scope, impact-only emphasis and EU/global perimeter choices remain consultation inputs until authority resolves.

Disposition: SCOPE_DELTA, REPORTING_CHANGE; AWAIT_AUTHORITY.

Acceptance criteria

Scenario	Expected behavior
Parliament non-objection exists but no verified OJ act is resolved	Revised ESRS remains staged; no legal activation.
Revised ESRS and Voluntary Standard have different authority evidence	Resolve and activate independently.
2023 concept maps to two revised concepts	No automatic duplication of the historic value; relationship requires semantic review.
Supplier self-declares 1,000 employees	Preserve declaration and provenance; evaluate CSRD ceiling under the applicable policy.
Supplier self-declares 1,001 employees	The specific protected-undertaking ceiling does not apply solely by that rule; other legal/policy constraints remain independently evaluated.
Supplier size is unknown or contradictory	Fail closed to an unresolved entitlement decision; do not assume permission to ask.
ESRS-40a exposure draft changes	Update candidate profile only; no mandatory filing behavior changes.

Cross-regime collisions

X-01 — CSRD vs CSDDD request rules. The CSRD Article 29ca protected-undertaking ceiling and CSDDD Article 8 partner safeguard have different thresholds, purposes and legal tests. They should execute as separate entitlement policies over the same supplier-contribution substrate.

X-03 — semantic concept vs filing taxonomy. ESRS concept migration belongs to the semantic layer; XBRL/ESEF activation belongs to Regulatory Infrastructure.

X-06 — corporate disclosure vs sustainable finance. Corporate values can feed finance projections, but do not by themselves prove Taxonomy alignment or satisfy every PAI definition.

Canonical specs reviewed / requiring follow-up

Reviewed:

• Pergamum Pulse XBRL Taxonomy Runtime Activation;
• Pergamum Pulse universal lifecycle registry;
• EPU Supplier Contribution Architecture.

Follow-up review before Hecate readiness:

• FOGE requirement/question-generation contract;
• Pergamum Pulse change-candidate/applicability contracts;
• canonical ESRS semantic mapping specifications;
• any existing reporting-profile resolver.

Weekly cohort history

Cohort	Intelligence retained	Integration decision
2026-W36	Revised datapoints; pending revised ESRS; supplier ceiling; ESRS-40a consultation	Staged migration and request-policy candidates.
2026-W37	Interoperability/outreach signals	WATCH; no public technical decision inferred from closed meetings.
2026-W38	Parliament non-objection; verified Directive 2026/470 request ceiling	Integrated 2026-09-15: reuse canonical authority/XBRL architecture; extend EPU Supplier Contributions with legal request entitlement; keep ESRS-40a and final mappings staged.

What changed in ZAYAZ? No reporting standard was activated. The important architecture delta is the proposed CSRD request-entitlement gate over the existing EPU supplier-contribution flow; revised-ESRS activation and mapping are staged through existing canonical Pergamum Pulse/XBRL mechanisms.

2026-W39 Architecture Integration

New authority events

ID	Finding	Classification / disposition
CD-W39-01	EFRAG released the Draft XBRL Taxonomy for the Revised ESRS on 17 September 2026; consultation closes 11 November. It contains the same datapoints as the August list plus technical XBRL attributes.	TECHNICAL_RESOURCE; TAXONOMY_CHANGE, INTEROPERABILITY_DELTA; technical capture PROPOSED_DELTA, filing authority AWAIT_AUTHORITY.
CD-W39-02	The Commission continues to list the revised ESRS and separate Voluntary Standard as not in force until OJ publication. Parliament's 11 September non-objection remains procedure evidence only.	LEGAL_ACT; SCRUTINY_CLEARED_PENDING_OJ; AWAIT_AUTHORITY.
CD-W39-03	Directive (EU) 2026/470 directly confirms the CSRD protected-undertaking rule: no more than 1,000 employees, optional self-declaration subject to manifest-error protection, and a right to decline reporting-purpose requests exceeding the voluntary standard.	LEGAL_ACT; FORM_CHANGE, REQUEST_RIGHTS_DELTA; supports unregistered candidate: regulatory request-entitlement gate.
CD-W39-04	ESRS-40a remains consultation-stage.	PROPOSAL; WATCH.

Architecture decision

The new XBRL taxonomy should be treated as a candidate manifestation of revised-ESRS concepts, not as a new canonical identity and not as filing authority.

Required flow:

official EFRAG package → source capture → rights → immutable taxonomy release registration → release diff → semantic mapping review → optional Runtime activation for authorised technical purposes → later filing authority if/when separately authorised

The repository already contains this architecture. Therefore the W39 change is to route the 17 September release through the existing Pergamum Pulse pipeline.

The supplier-form implication is also now firmer: the CSRD protected-undertaking rule is a reporting-purpose entitlement rule and explicitly does not displace requests required under other EU or national law. FOGE/EPU contribution generation therefore needs a purpose-specific entitlement receipt rather than a universal supplier-size flag.

Acceptance criteria

• Registering the 2026 draft taxonomy does not deactivate the 2024 release.
• A changed QName or XBRL element does not by itself create a new canonical sustainability concept.
• Revised ESRS remain unavailable as a legally active production reporting profile until exact authority/applicability conditions are satisfied.
• A supplier self-declaration may support CSRD protected status unless manifestly incorrect; the evidence and policy version remain replayable.
• A CSRD-protected supplier decision cannot be reused as a CSDDD entitlement decision.

Canonical specs to review

• Pergamum Pulse publisher-package XBRL capture workflow;
• XBRL taxonomy release identity and observation registries;
• Semantic Mapping and Crosswalk Specification;
• PP-to-FOGE Requirement Execution Contract;
• EPU Supplier Contribution Architecture.

W39 history

What changed in ZAYAZ? Revised-ESRS digital readiness moved from “await taxonomy publication” to “capture and diff the published draft taxonomy using existing governance.” Legal activation remains blocked. Supplier-request entitlement moved closer to implementation because the relevant CSRD rule is now article-level verified.

W39 source/evidence register

All entries below were retrieved/rechecked 2026-09-22.

Event	Authoritative source	Locator
CD-W39-01	EFRAG — Draft ESRS XBRL Taxonomy for Revised ESRS	Publication 17.09.2026; consultation deadline 11.11.2026; taxonomy/datapoint alignment and non-mandatory tagging statement.
CD-W39-02	European Commission — CSRD delegated acts; European Parliament — 2026/2810(DEA)	Commission 3 July 2026 entries state not in force until OJ publication; Parliament records 11.09.2026 non-objection.
CD-W39-03	EUR-Lex — Directive (EU) 2026/470	Amendment to Accounting Directive Article 19a(3): protected undertaking ≤1,000 employees; self-declaration; right to decline reporting-purpose requests exceeding voluntary standards.
CD-W39-04	EFRAG — ESRS-40a consultation	Consultation period 23.07.2026–31.10.2026.