EU Sustainability Regulatory Architecture Integration

This is the governing rule document for the permanent weekly ZAYAZ regulatory architecture-integration process. Monday intelligence identifies developments; Tuesday integration determines whether those developments justify a change to ZAYAZ. The output must answer: What changed in ZAYAZ this week because of external regulatory developments? NO_ACTION is a valid outcome.

The governing principle is:

Regulatory intelligence discovers change. Architecture Integration determines whether that change belongs in ZAYAZ.

A regulatory publication, committee vote, guidance note, taxonomy package or research result is never an automatic production-change instruction.

Document map and scope

Document	Core responsibility
Corporate Disclosure	CSRD, ESRS, ESRS-40a, Voluntary Standard; disclosure-side ESEF requirements
Sustainable Finance	EU Taxonomy and delegated acts; SFDR
Supply-Chain Due Diligence	CSDDD, EUDR, Forced Labour Regulation
Product Sustainability	PEF/OEF/PEFCR/OEFSR/EF datasets, ESPR/DPP, Batteries, CBAM
Claims & Market Communication	Green Claims and Empowering Consumers for the Green Transition (EmpCo)
Regulatory Infrastructure	ESEF/ESRS XBRL, authority/applicability profiles, schemas, code lists, portals, APIs and cross-regime evidence contracts

These documents cover the twelve core regime families. ESEF has linked disclosure and infrastructure views. Green Claims and EmpCo remain separate legal instruments and must never share an authority state merely because they concern similar claims. CBAM has its primary integration home in Product Sustainability while linking to supply-chain evidence, finance and regulatory infrastructure.

Second-tier watchlist: REACH/CLP; Packaging and Packaging Waste Regulation (PPWR); product-specific ecodesign acts; Critical Raw Materials Act; Industrial Emissions Directive; methane regulation; ETS/ETS2; EU climate-target legislation; public-country-by-country XBRL taxonomy; and sector-specific sustainability legislation. A watch item is promoted only when it materially changes collection, calculation, mapping, evidence, reporting, transmission, claims or product strategy.

Weekly operating contract

Monday — Regulatory Intelligence Intake

The Monday cohort should identify consequential changes, distinguish their authority, explain practical impact and flag candidate architecture consequences.

Tuesday — Architecture Integration

The Tuesday review SHALL:

1. read the latest Monday cohort and preserve its ISO week;
2. reopen authoritative sources and record publication/event dates, retrieval dates, identifiers and authority state;
3. separate new events, unchanged carry-forwards, corrections and supplemental baseline findings discovered during architecture review;
4. read the relevant canonical ZAYAZ architecture at a recorded commit before calling anything an architecture delta;
5. identify whether the external development is already supported by existing architecture, requires a policy/profile update, requires a genuine new contract, or requires no action;
6. run cross-regime collision and shared-evidence analysis;
7. update only these integration documents on a review branch unless a separately governed change explicitly authorises edits elsewhere;
8. identify canonical specifications requiring review rather than casually changing them;
9. propose a Hecate Need only where the architecture is sufficiently determined and does not duplicate an existing canonical capability;
10. append the cohort history and answer what changed in ZAYAZ.

The normal repository branch naming convention is weekly-sustainability-intel/YYYY-Www-architecture-integration. Never merge to main automatically.

Authority, lifecycle and applicability

Do not create a second universal lifecycle

The canonical Pergamum Pulse lifecycle registry already defines the universal first-class object lifecycle vocabulary and explicitly requires workflow, review, adoption, projection and activation dimensions to remain orthogonal. Regulatory intelligence SHALL therefore not introduce a competing universal lifecycle enum.

The WSI authority states below are a specialised regulatory classification/profile used to describe legal and procedural authority. They must map to, rather than replace, the canonical lifecycle and constitutional runtime model.

Regulatory authority classification

Axis	Values and interpretation
Source kind	LEGAL_ACT, PROPOSAL, OFFICIAL_GUIDANCE, TECHNICAL_RESOURCE, SUPERVISORY_SIGNAL, RESEARCH
Regulatory authority state	PROPOSED, ADOPTED_PENDING_SCRUTINY, SCRUTINY_CLEARED_PENDING_OJ, ADOPTED_PENDING_OJ, IN_FORCE, SUPERSEDED, WITHDRAWN, NOT_APPLICABLE
Procedure evidence	Parliament and Council scrutiny events recorded separately; no institution's event proves another institution's event
Applicability	Entry into force, application date, reporting period, entity/product scope, transition and national transposition tracked independently
Verification	RECHECKED_OFFICIAL, CONVERSATION_REPORTED, BASELINE_WATCH, CONFLICT_REQUIRES_REVIEW
Architecture disposition	WATCH, NO_ACTION, AWAIT_AUTHORITY, AWAIT_TECHNICAL_SPEC, AWAIT_GUIDANCE, CANONICAL_REVIEW_REQUIRED, PROPOSED_DELTA, APPROVED_DELTA, IMPLEMENTED, VALIDATED

Guidance does not become IN_FORCE. A directive can be in force at EU level while national transposition and company application remain future. A technically valid package does not itself create legal, filing, publication or semantic-mapping authority.

Bitemporal requirement

Where a regulatory event can influence Runtime behavior, preserve at least:

• source publication/event time;
• legal effective/applicability time;
• ZAYAZ transaction/knowledge time;
• reporting-period applicability;
• supersession/correction lineage;
• authority and provenance of the transition.

This aligns with the canonical Pergamum Pulse and Constitutional Runtime requirements rather than creating a WSI-specific temporal model.

Regulatory Delta Classification

Use one or more tags and one architecture disposition.

FORM_CHANGE, RULE_CHANGE, TAXONOMY_CHANGE, DATASET_CHANGE, CALCULATION_CHANGE, EVIDENCE_CHANGE, WORKFLOW_CHANGE, API_SUBMISSION_CHANGE, REPORTING_CHANGE, CLAIMS_CHANGE, SCOPE_DELTA, EFFECTIVE_DATE_DELTA, REQUEST_RIGHTS_DELTA, ASSURANCE_DELTA, INTEROPERABILITY_DELTA, PRODUCT_STRATEGY_DELTA, WATCH, NO_ACTION.

A useful integration distinction is:

• architecture already supports it → document canonical alignment and normally NO_ACTION or a bounded policy/profile change;
• architecture exists but needs a new governed profile/rule → PROPOSED_DELTA or CANONICAL_REVIEW_REQUIRED;
• genuinely missing architectural responsibility → candidate Hecate Need after duplicate check;
• authority or technical specification unresolved → AWAIT_AUTHORITY, AWAIT_TECHNICAL_SPEC or AWAIT_GUIDANCE.

Required integration record

item_id: WSI-YYYY-Www-DOMAIN-NN
cohort: YYYY-Www
event_date: null
integration_date: null
source_kind: null
source_url: null
instrument_id: null
article_or_annex: null
source_version: null
retrieved_at: null
verification: null
authority_state: null
parliament_scrutiny: null
council_scrutiny: null
entry_into_force: null
application_date: null
reporting_period: null
national_transposition: null
scope_and_exceptions: null
classification: []
owning_domain: null
cross_regime_links: []
finding: null
architecture_implication: null
canonical_baseline_commit: null
canonical_specs_reviewed: []
disposition: null
decision_and_rationale: null
roadmap_stage: null
contract_changes: []
acceptance_criteria: []
validation_results: []
risks: []
open_questions: []
owner: unassigned
hecate_need: null
branch_or_review: null
supersedes_or_corrects: null
next_review_trigger: null

Canonical architecture reconciled in 2026-W38

The first Tuesday integration reviewed the actual repository rather than treating the WSI documents as a greenfield architecture. This materially changes the recommendations.

Canonical asset	Existing responsibility	WSI consequence
config/system/pergamum-pulse/pergamum-pulse-lifecycle-registry.json	Universal lifecycle with authority/reason/effective time/transaction time/provenance on transitions; orthogonal specialised profiles	Do not create a parallel WSI lifecycle. Add regulatory authority/applicability as a specialised profile.
content/standards/pergamum-pulse/pergamum-pulse-xbrl-taxonomy-runtime-activation.mdx	Separates registration, release, Runtime activation, legal authority, semantic mapping, filing, publication and redistribution	Revised-ESRS/ESEF integration should reuse this activation chain. No second XBRL activation subsystem is justified.
config/system/pergamum-pulse/pergamum-pulse-rights-vocabulary.json	Canonical processing operations and permission states; omitted permission is not granted	Reused regulatory evidence, passport exposure and claim support must compose with this rights gate rather than invent another permission vocabulary.
content/eco-product-unit/epu-supplier-contributions.mdx	Resolve → anticipate → acquire the delta → validate → reuse, No Ask Before Reuse, requirement-driven minimal questions	CSRD/CSDDD do not justify another questionnaire system. The genuine delta is a legal request-entitlement/purpose gate before a contribution is issued.
content/key-zayaz-features/pef/pef-lca-implementation-roadmap.mdx	Governed Method Profiles, factor/dataset resolution, evidence, uncertainty, rights and weekly PEF integration	The July 2026 EF fallback guidance is a bounded method/dataset-policy update, not a new PEF architecture.

This reconciliation is a major purpose of the Tuesday cycle: external regulation should strengthen or extend canonical architecture, not cause duplicate subsystem creation.

Cross-regime collision register

ID	Collision	Required resolution
X-01	CSRD protected-value-chain request ceiling versus CSDDD partner information-request safeguard	Separate legal bases, employee tests and purposes; execute as separate entitlement policies over the same EPU contribution substrate.
X-02	Reusable supplier evidence versus EUDR parcel/product specificity	Reuse only when product/commodity, parcel, timing, legality, authority and rights match.
X-03	Canonical concept versus ESRS/ESEF/ISSB/GRI labels	Version manifestations and boundaries; mapping is not proof of equivalence.
X-04	Corporate emissions, PEF, Batteries and CBAM	Preserve separate functional units, boundaries, allocation, method profiles and verification rules.
X-05	PEF/footprint result versus permissible market claim	A result is evidence, not publication authority. Claims review owns publication eligibility.
X-06	EU Taxonomy eligibility/alignment versus SFDR product category	Separate assertions, evidence and versioned rules.
X-07	Passport transparency versus evidence confidentiality/licensing	Reuse canonical Pergamum Pulse rights before public exposure.
X-08	Procedure-page status versus OJ/legal effectiveness	Preserve conflicting observations; block legal activation until the authoritative commencement conditions are resolved.
X-09	EmpCo binding consumer-law obligations versus Green Claims proposal	Apply EmpCo independently. Do not wait for or import unadopted Green Claims requirements.
X-10	CSDDD future ESAP statements versus CSRD/ESEF filings	Share infrastructure where possible, but keep content, legal basis, reporting profile and submission authority separate.

Hecate dependency queue after canonical reconciliation

These are descriptive work-item candidates only. They are not created, approved, registered or canonically identified Hecate Needs. No governed Need identifier or lifecycle state may be assigned here before the applicable registry grants one.

Descriptive work item	2026-W38 editorial disposition	Gate
unregistered candidate: regulatory authority/applicability profile Regulatory authority/applicability profile	REFRAME	Extend canonical Pergamum/KORS/CRF authority and applicability; do not create a new universal lifecycle. Inspect existing change-candidate/application contracts before Need drafting.
unregistered candidate: regulatory request-entitlement gate Regulatory request-entitlement gate for EPU Supplier Contributions	STRONGEST NEXT CANDIDATE	Directive 2026/470 now provides verified CSRD and CSDDD request rules. Need should add purpose/entitlement policy before existing contribution generation, not duplicate EPU Supplier Contributions.
unregistered candidate: ESRS concept/reporting-profile migration ESRS concept/reporting-profile migration	CANDIDATE / AWAIT_TECHNICAL_SPEC	Use current semantic/XBRL architecture; final revised datapoint resources and XBRL taxonomy still govern the migration boundary.
unregistered candidate: method and dataset resolution receipts Method and dataset resolution receipts	ABSORBED / NO NEW NEED	Existing PEF/LCA roadmap already owns Method Profiles, factor/dataset resolution and evidence. Review that roadmap for the July 2026 guidance instead.
unregistered candidate: non-XBRL regulatory submission/passport adapters Non-XBRL regulatory submission/passport adapters	REFRAME	XBRL activation is already governed. Retain future candidate only for EUDR/DPP/CBAM or other channels after exact schemas/APIs are inspected.
unregistered candidate: sustainability claim publication gate Sustainability claim publication gate	ELEVATED CANDIDATE	EmpCo applies from 27 September 2026. Confirm national profiles and existing publication/approval architecture before Need is marked ready.

2026-W38 architecture decisions

Decision 1 — Revised ESRS remains staged, not activated

Parliament recorded non-objection on 11 September 2026, but no verified OJ-published revised-ESRS regulation was identified during this review. EFRAG also states that the revised ESRS become legally effective after OJ publication following scrutiny. ZAYAZ should therefore stage the revised ESRS and Voluntary Standard without granting legal activation.

Disposition: AWAIT_AUTHORITY for legal activation; PROPOSED_DELTA only for migration preparation.

Decision 2 — Supplier data architecture is extended, not replaced

Directive (EU) 2026/470 was verified at source for the CSRD protected-undertaking rule and CSDDD Article 8 request safeguards. The existing EPU Supplier Contribution Architecture already implements resolution-before-request and minimal unresolved acquisition.

The genuine architecture delta is a regime-specific request-entitlement gate that evaluates legal basis, purpose, supplier/partner size evidence, alternative-source checks and evidence gap before an EPU contribution request is permitted.

Disposition: PROPOSED_DELTA; candidate unregistered candidate: regulatory request-entitlement gate.

Decision 3 — PEF fallback is a policy-profile change

The Commission's 14 July 2026 EF dataset guidance fits the existing PEF/LCA roadmap's Method Profile and factor/dataset-resolution architecture. No new PEF architecture is warranted.

Disposition: CANONICAL_REVIEW_REQUIRED for the PEF/LCA roadmap; no new Hecate Need.

Decision 4 — XBRL/ESEF architecture already contains the required safety boundary

Canonical Pergamum Pulse XBRL activation already separates technical registration and Runtime activation from legal authority and filing authority. Future revised-ESRS taxonomy ingestion should reuse that chain.

Disposition: NO_ACTION for generic activation architecture; AWAIT_TECHNICAL_SPEC for the revised taxonomy itself.

Decision 5 — Claims governance becomes near-term

EmpCo applies from 27 September 2026, while the Green Claims proposal remains non-binding and subject to unresolved procedure/withdrawal status. Claims governance must therefore prioritise applicable EmpCo/national consumer-law profiles and keep Green Claims in AWAIT_AUTHORITY.

Disposition: CANONICAL_REVIEW_REQUIRED; unregistered candidate: sustainability claim publication gate elevated but not ready.

Weekly cohort history

Cohort	Intake	Architecture Integration outcome
2026-W36	ESRS migration material; supplier safeguards; ESEF gating; PEF fallback; ESRS-40a consultation; Taxonomy advice watch	Imported retrospectively; no historical production change claimed.
2026-W37	Continued ESRS gate; interoperability/outreach signals; ORBIT research; configurable policy and concept identity	Imported retrospectively; research/process signals did not create legal obligations.
2026-W38	Parliament ESRS non-objection; SFDR committee event; twelve-family scope; six-domain model	Integrated 2026-09-15. Canonical comparison completed for key Pergamum Pulse, EPU Supplier Contribution and PEF/LCA assets. One clear proposed extension emerged: regulatory request entitlement over existing supplier contributions. PEF and XBRL recommendations were narrowed to existing canonical architecture. Claims governance was elevated because EmpCo applies 27 September. No production rule was activated.

What changed in ZAYAZ this week because of external regulatory developments?

No production compliance rule was activated and no new generic subsystem was justified. The main architectural change is sharper: ZAYAZ should extend the existing EPU Supplier Contribution flow with a regime-specific legal request-entitlement gate for CSRD and CSDDD. Canonical review also showed that Pergamum Pulse already provides the lifecycle/activation/rights foundations required for regulatory ingestion and XBRL, and the PEF/LCA roadmap already owns factor/dataset-resolution governance. Those findings retire several duplicate architecture proposals. EmpCo's 27 September 2026 application makes claims publication governance the next near-term review area, while revised ESRS remains staged pending authoritative OJ activation evidence.

2026-W39 Architecture Integration — 22 September 2026

Cohort decision

The Monday 21 September intake was rechecked against EFRAG, the European Commission, EUR-Lex, ESMA and the European Parliament. The material W39 signals are:

1. EFRAG published the Draft XBRL Taxonomy for the Revised ESRS on 17 September 2026 and opened consultation until 11 November 2026. It contains the same datapoints as the August draft datapoint list plus the technical attributes required for XBRL representation. EFRAG plans submission of the final taxonomy to ESMA and the Commission by year-end. Digital tagging is not yet mandatory.
2. The revised ESRS remain staged, not legally activated. Parliament recorded non-objection on 11 September, while the Commission still states that the revised ESRS and the separate Voluntary Standard are not in force until OJ publication.
3. Directive (EU) 2026/470 now provides article-level confirmation of both the CSRD protected-undertaking request ceiling and the separate CSDDD Article 8 partner-information safeguard.
4. The Green Claims proposal remains pending. EmpCo applies from 27 September 2026.
5. No new PEF method revision superseded the 14 July 2026 EF dataset guidance.
6. SFDR and the 2026 Taxonomy TSC revisions remain proposal/draft-stage and do not justify production migration.

Canonical reconciliation

The current canonical baseline was rechecked at b6472002a3842d6bed206848a34283339377074a.

The repository already contains:

• governed ESRS XBRL capture and registration infrastructure;
• xbrl-taxonomy-release-identity-registry.json;
• xbrl-taxonomy-release-observation-registry.json;
• the publisher-package workflow requiring each later taxonomy release to be captured independently and compared through the release-diff workflow;
• Pergamum Pulse XBRL Runtime activation architecture;
• Pergamum Pulse Semantic Mapping and Crosswalk Specification;
• EPU Supplier Contribution Architecture;
• the PEF/LCA Implementation Roadmap.

This changes the W39 architectural conclusion: the new EFRAG taxonomy is not a new architecture need. It is a new governed release to be processed by architecture that already exists.

The existing observation that the 2026 taxonomy was unpublished can now transition to a governed source-capture candidate for the official 17 September release. Registration, semantic mapping, Runtime activation, filing authority and legal authority remain separate decisions.

Hecate queue — W39 disposition

Descriptive work item	W39 editorial disposition	Reason
unregistered candidate: regulatory authority/applicability profile Regulatory authority/applicability profile	CANONICAL_REVIEW_REQUIRED	Still useful, but must extend existing Pergamum/CRF authority semantics rather than create a new lifecycle.
unregistered candidate: regulatory request-entitlement gate Regulatory request-entitlement gate	READY_FOR_NEED_DRAFT	Directive 2026/470 text now directly verifies both CSRD and CSDDD request tests, and EPU Supplier Contributions already supplies the correct acquisition substrate.
unregistered candidate: ESRS concept/reporting-profile migration ESRS migration / taxonomy	NO_NEW_NEED for capture architecture; AWAIT_TECHNICAL_SPEC for final taxonomy	Existing XBRL capture/diff/mapping architecture is sufficient. A later bounded migration Need may be justified only for semantic/reporting-profile consequences not already covered.
unregistered candidate: method and dataset resolution receipts PEF dataset resolution	NO_NEW_NEED	Existing PEF/LCA roadmap owns the capability.
unregistered candidate: non-XBRL regulatory submission/passport adapters Non-XBRL submission adapters	AWAIT_TECHNICAL_SPEC	Remains channel-specific for EUDR/DPP/CBAM, not XBRL.
unregistered candidate: sustainability claim publication gate Sustainability claim publication gate	READY_FOR_DETAILED_CANONICAL_REVIEW	EmpCo applies 27 September; Green Claims remains pending. Existing publication/conformance assets must be reconciled before Need drafting.

New/updated cross-regime collision

X-11 — draft ESRS taxonomy versus filing authority. A technically registered and semantically mapped 2026 ESRS taxonomy remains a technical resource. It must not acquire legal, filing or customer-publication authority until the applicable ESEF regulatory framework and exact Runtime authority chain permit those uses.

W39 acceptance criteria

• Capturing the 17 September EFRAG taxonomy SHALL NOT activate it for filing.
• The 2024 EFRAG taxonomy SHALL remain replayable after registration of the 2026 draft taxonomy.
• A taxonomy release diff SHALL distinguish technical identity changes from semantic-equivalence decisions.
• A CSRD supplier request SHALL fail closed where protected-undertaking status or request purpose is unresolved.
• A CSDDD partner request below the 5,000-employee safeguard SHALL preserve evidence that alternative means were evaluated.
• EmpCo applicability SHALL be resolved independently from Green Claims proposal status.
• Proposal-stage SFDR or Taxonomy criteria SHALL never overwrite the active production profile.

Sources rechecked

• EFRAG, 17 September 2026, Draft ESRS XBRL Taxonomy consultation.
• Commission CSRD delegated-acts register.
• European Parliament procedure 2026/2810(DEA).
• Directive (EU) 2026/470 and consolidated CSDDD Article 8.
• ESMA Electronic Reporting.
• Commission EF transitional guidance, 14 July 2026.
• Commission sustainable-consumption/EmpCo pages.
• Parliament SFDR procedure 2025/0361(COD).
• Commission Taxonomy delegated-acts register.

W39 outcome

What changed in ZAYAZ this week because of external regulatory developments?

The most concrete change is not a new subsystem but a new governed taxonomy release entering an existing constitutional pipeline. The 17 September EFRAG taxonomy should now be captured, registered and diffed as a technical candidate while legal/filing activation remains off. The supplier-request entitlement gate is now sufficiently grounded in Directive (EU) 2026/470 to move from architecture concept to a Hecate Need draft. EmpCo makes claim-publication controls the next urgent canonical review. No production regulatory profile was activated.

W39 authoritative source register

The W39 integration decisions above were rechecked on 2026-09-22. A source locator is required before any item may be marked RECHECKED_OFFICIAL.

Source	Authority	Locator / use
EFRAG — Draft ESRS XBRL Taxonomy, 17 Sep 2026	EFRAG	Publication date 17.09.2026; consultation deadline 11.11.2026; technical taxonomy status and non-mandatory tagging statement.
European Commission — CSRD implementing and delegated acts	European Commission	3 July 2026 revised ESRS and Voluntary Standard entries; both stated as not in force until OJ publication.
European Parliament — 2026/2810(DEA)	European Parliament	Delegated-act scrutiny event for revised ESRS; Parliament non-objection recorded 11.09.2026.
EUR-Lex — Directive (EU) 2026/470	Official Journal / EUR-Lex	Accounting Directive Article 19a protected-undertaking/value-chain-cap amendments and CSDDD Article 8 request safeguards.
EFRAG — ESRS-40a consultation	EFRAG	Consultation period 23.07.2026–31.10.2026.
European Commission — Taxonomy delegated acts	European Commission	March 2026 TSC amendments still identified as not yet adopted / not in force.
European Commission — EF transitional dataset guidance	European Commission DG ENV	14.07.2026 transitional EF dataset hierarchy and disclaimer rule.
European Commission — Sustainable consumption / EmpCo	European Commission	Directive (EU) 2024/825 transposition/application dates; application from 27.09.2026.

Unregistered work-item labels

Any work item described in this WSI document set is descriptive only until a canonical registry assigns an identifier. WSI SHALL NOT mint HN-*, Hecate Need, policy, ruleset, event, schema, artifact or other governed identifiers. Per AGENTS.md, missing registry entries must be reported for explicit approval. Descriptive readiness phrases such as “ready for Need drafting” describe editorial maturity only and SHALL NOT be interpreted as a governed Hecate lifecycle state.

2026-W40 Architecture Integration — 29 September 2026

Authority changes

The Monday 28 September cohort was rechecked against primary sources.

• Delegated Regulation (EU) 2026/1563 was published in the Official Journal on 21 September 2026. It enters into force on 10 November 2026, applies to financial years beginning on or after 1 January 2027, and contains the FY2026 transition options in Article 2.
• Delegated Regulation (EU) 2026/1560 was published on 21 September 2026 and is now in force. Its Article 3 / Annex II value-chain-cap profile applies from financial years beginning on or after 1 January 2027.
• Directive (EU) 2024/825 reached its scheduled application date on 27 September 2026. Production use still requires the applicable national implementation to resolve.
• EFRAG's 17 September revised-ESRS XBRL taxonomy remains a draft technical taxonomy under consultation. ESMA still states that sustainability markup is not mandatory until the relevant ESEF marking rules are adopted.
• No W40 source superseded the current CSDDD amendment/guidance timetable or the July 2026 PEF transitional dataset guidance. SFDR and the broad Taxonomy TSC revision remain non-binding work in progress.

Regulatory delta classification

Development	Delta	ZAYAZ disposition
Revised ESRS OJ publication and transition dates	EFFECTIVE_DATE_DELTA, DATAPOINT_DELTA, REPORTING_DELTA, WORKFLOW_DELTA, INTEROPERABILITY_DELTA	Move from AWAIT_AUTHORITY to governed ESRS 2026 release preparation.
Voluntary Standard / Annex II cap	FORM_DELTA, SUPPLIER_DATA_DELTA, RIGHTS_DELTA, WORKFLOW_DELTA	Add the final Annex II profile to the existing regulatory request-entitlement design; keep the policy future-dated.
Directive (EU) 2024/825 application date	CLAIMS_DELTA, EFFECTIVE_DATE_DELTA, ENFORCEMENT_DELTA	Resolve national market-communication profiles through existing publication governance.
Draft revised-ESRS XBRL taxonomy	TAXONOMY_DELTA, INTEROPERABILITY_DELTA	Continue governed capture/diff/mapping; AWAIT_TECHNICAL_SPEC and AWAIT_AUTHORITY for filing.
PEF, CSDDD, SFDR and Taxonomy items without new authority	no new production delta	NO_ACTION, WATCH, AWAIT_GUIDANCE or AWAIT_AUTHORITY as applicable.

Canonical reconciliation

The final legal ESRS does not require a new reporting engine. The material work is a governed ESRS 2026 reporting-profile release with exact legal version, reporting-period applicability and FY2026 transition mode. Historic ESRS 2023 reporting remains replayable.

The final Voluntary Standard does not create another questionnaire architecture. Annex II becomes a concrete governed input to the request-entitlement capability already identified in W39. It must remain purpose-specific and separate from CSDDD.

Directive (EU) 2024/825 also does not justify another publication subsystem. Canonical review of the Constitutional Publication Framework shows existing controls for Publication Assertions, evidence sufficiency, jurisdiction, audience, approval, release, correction and withdrawal. The remaining work is a bounded legal profile/rule set for market-facing sustainability communications.

Hecate editorial queue

No governed identifier is minted by this WSI cycle.

Descriptive work item	W40 disposition
regulatory request-entitlement gate	READY_FOR_NEED_DRAFT — final Annex II authority and temporal scope are now available.
ESRS 2026 reporting-profile migration	READY_FOR_NEED_DRAFT — legal version and transition dates are now authoritative; digital filing stays outside scope.
revised-ESRS XBRL processing	NO_NEW_NEED / AWAIT_TECHNICAL_SPEC — existing Pergamum Pulse pipeline owns it.
PEF dataset fallback	NO_NEW_NEED / NO_ACTION — canonical PEF/LCA roadmap already contains the policy.
sustainability communication publication gate	NO_NEW_GENERIC_NEED — generic controls are already CPF-owned; only bounded legal profiles remain.

Cross-regime additions

X-12 — FY2026 ESRS transition versus semantic/taxonomy mixing. A reporting instance must bind one governed transition mode and the exact permitted legal ESRS version. Draft technical taxonomy concepts cannot silently change that legal basis.

X-13 — EU legal status versus EEA incorporation. EFTA records Regulations 2026/1563 and 2026/1560 as EEA-relevant but still under scrutiny for incorporation. EU and Norway/EEA applicability therefore remain separate authority states.

Acceptance criteria

1. FY2026 reporting resolves a legally permitted transition route and records which version was used.
2. FY2027 reporting can resolve the 2026 ESRS release without mutating historical reports.
3. Annex II evaluation is versioned, purpose-specific and temporally gated.
4. Draft XBRL registration never grants filing authority.
5. EU and EEA/Norway applicability can diverge on the same date.
6. Directive (EU) 2024/825 market-communication decisions resolve the applicable national profile.
7. PEF fallback behavior continues through the existing canonical roadmap rather than a duplicate receipt family.

What changed in ZAYAZ this week because of external regulatory developments?

The revised ESRS and Voluntary Standard moved from pending authority to published EU legal releases. ZAYAZ can now prepare the ESRS 2026 reporting profile and final Annex II request-cap profile under existing governance. Production activation remains separate: revised ESRS is future-effective, the cap is future-dated, sustainability ESEF filing is not yet authorised, and EEA incorporation remains pending. Directive (EU) 2024/825 now requires immediate jurisdiction-profile review for market-facing sustainability communications. No new generic PEF, CSDDD, finance or publication subsystem is justified.

W40 authoritative source register

All entries below were rechecked 2026-09-29.

Event	Authoritative source	Authority use
Revised ESRS	EUR-Lex — Delegated Regulation (EU) 2026/1563	OJ publication, FY2026 transition, entry and application dates.
Voluntary Standard	EUR-Lex — Delegated Regulation (EU) 2026/1560	In-force standard and Annex II cap profile.
EEA state	EFTA — 32026R1563; EFTA — 32026R1560	EEA-relevant; incorporation still pending.
Revised-ESRS XBRL	EFRAG — draft taxonomy consultation	Technical taxonomy only; consultation to 11.11.2026.
ESEF sustainability	ESMA — Electronic Reporting	No mandatory sustainability markup until marking rules are adopted.
Directive (EU) 2024/825	European Commission — Sustainable consumption; EUR-Lex	Application date and primary legal source.
CSDDD	European Commission — Corporate sustainability due diligence	Current amendment/application/guidance timetable.
PEF	European Commission — EF transitional guidance	Current fallback guidance.
SFDR	European Parliament — 2025/0361(COD)	Proposal-stage procedure.
Taxonomy TSC	European Commission — Taxonomy delegated acts	Draft revisions remain not adopted.

2026-W41 Architecture Integration — 6 October 2026

Monday cohort and authority recheck

The 5 October regulatory-intelligence cohort did not identify a new binding EU sustainability instrument that supersedes the W40 baseline. The material work this week is therefore authority separation, technical-resource versioning and canonical reconciliation rather than production-rule activation.

ID	Development	Authority state	Delta / disposition
W41-01	Delegated Regulation (EU) 2026/1563 remains published but does not enter into force until 10 November 2026; FY2026 transition choices and FY2027 application remain unchanged.	LEGAL_ACT; published-not-in-force	EFFECTIVE_DATE_DELTA, REPORTING_CHANGE; reporting-profile preparation continues, no premature activation.
W41-02	Delegated Regulation (EU) 2026/1560 remains in force; its Article 3 value-chain-cap regime applies for financial years beginning on or after 1 January 2027.	LEGAL_ACT; IN_FORCE with future reporting-period applicability	FORM_CHANGE, REQUEST_RIGHTS_DELTA; continue bounded supplier request-entitlement work.
W41-03	EFRAG's revised-ESRS datapoint list remains draft support material until the fatal-flaw process closes 23 October 2026; the revised-ESRS XBRL taxonomy remains under consultation until 11 November 2026.	TECHNICAL_RESOURCE	TAXONOMY_CHANGE, INTEROPERABILITY_DELTA; AWAIT_TECHNICAL_SPEC.
W41-04	EFRAG has updated non-mandatory guidance for the Voluntary Standard and states that legacy VSME digital templates/taxonomies are being replaced; updated VS digital material is scheduled for Q4/November 2026.	OFFICIAL_GUIDANCE / TECHNICAL_RESOURCE	FORM_CHANGE, TAXONOMY_CHANGE; legal Annex II remains the entitlement authority; AWAIT_TECHNICAL_SPEC for the replacement package.
W41-05	CSDDD legal dates and the Commission guidance timetable remain unchanged.	LEGAL_ACT + future OFFICIAL_GUIDANCE	NO_ACTION on core architecture; guidance-sensitive parameters remain AWAIT_GUIDANCE.
W41-06	No new Environmental Footprint Recommendation was identified. Recommendation (EU) 2021/2279 and the 14 July 2026 dataset-transition guidance remain the current baseline.	LEGAL_ACT/RECOMMENDATION + OFFICIAL_GUIDANCE	WATCH; no Tuesday roadmap change.
W41-07	EU Taxonomy KPI/disclosure simplification remains in technical-advice/consultation territory; ESMA final advice is due by end-October. SFDR and broad Taxonomy-TSC revisions remain non-final.	PROPOSAL / TECHNICAL_ADVICE	WATCH, AWAIT_AUTHORITY.
W41-08	Directive (EU) 2024/825 remains applicable from 27 September 2026; no new EU-level claims instrument changed the W40 architecture conclusion.	LEGAL_ACT	NO_ACTION for generic publication architecture; continue jurisdictional profile mapping.
W41-09	EFTA still records Regulations 2026/1563 and 2026/1560 as under scrutiny for EEA incorporation.	EEA applicability evidence	AWAIT_AUTHORITY; do not equate EU status with Norway/EEA activation.

Canonical reconciliation at current main

The canonical baseline has advanced materially since the W40 branch was cut. Current main now contains the Pergamum Pulse Core 1.0 Regulatory Temporal Profile specification and migration, including immutable pp.regulatory_temporal_profile and pp.regulatory_applicability_period contracts plus a governed regulatory legal-status registry.

This resolves the architecture question previously described as the unregistered candidate “regulatory authority/applicability profile”.

Decision: WSI SHALL NOT create a parallel authority/applicability profile. External regulatory facts SHALL project into the canonical Pergamum Pulse regulatory-temporal/applicability model, subject to the normal PP admission, evidence, versioning and release rules. Runtime use remains separately governed and must not be inferred from repository presence alone.

The following bounded work remains sufficiently determined for later Hecate Need drafting, but no governed Need identifier is minted here:

• ESRS 2026 reporting-profile migration and transition proof: bind exact legal release, reporting year, FY2026 transition option, semantic mappings, assurance profile and historical replay.
• Regime-specific supplier request-entitlement gate: resolve CSRD and CSDDD purpose/threshold/alternative-source tests before the existing EPU Supplier Contribution flow issues a request.

The following do not justify new generic Hecate work:

• another XBRL activation subsystem;
• another regulatory lifecycle/temporal registry;
• another generic claims-publication gate;
• another PEF dataset-resolution subsystem.

New authority collision — X-14

X-14 — legal value-chain cap versus technical VS/VSME artefacts.

A field appearing in an EFRAG digital template, XBRL taxonomy, guidance workbook or legacy VSME artefact does not establish that a CSRD reporter may require that field from a protected value-chain undertaking.

The entitlement decision must resolve:

1. exact legal basis and reporting purpose;
2. applicable reporting period;
3. protected-undertaking status;
4. exact Regulation 2026/1560 Annex II scope;
5. then, separately, the technical field/taxonomy manifestation.

Legacy VSME templates must never be treated as the legal Annex II ceiling for the final Voluntary Standard.

Shared evidence

Supplier identity, employee-count evidence, product/activity evidence and prior contributions may be reused across CSRD, CSDDD, PEF and other regimes, but request authority and sufficiency remain purpose-specific. One regime's permission or restriction does not silently become another regime's rule.

W41 acceptance criteria

1. Regulation 2026/1563 cannot resolve as legally in-force before 10 November 2026.
2. FY2026 ESRS transition choice is explicit and replayable; no report silently mixes transition modes.
3. The legal Voluntary Standard/Annex II identity is distinct from EFRAG guidance, digital template and XBRL identities.
4. A legacy VSME template cannot grant or deny CSRD request entitlement.
5. Draft datapoint/XBRL resources can be captured and mapped without creating filing authority.
6. EU and EEA/Norway applicability resolve independently.
7. CSDDD request decisions preserve necessity and alternative-source evidence separately from CSRD cap decisions.
8. Proposal/advice-stage Taxonomy and SFDR material cannot alter production finance rules.
9. PEF research/method intelligence remains owned by the Friday/Saturday PEF/LCA process; Tuesday changes only authoritative regulatory PEF consequences.

What changed in ZAYAZ this week because of external regulatory developments?

No new production compliance rule or generic subsystem was activated. The most important W41 architecture result is a cleanup of authority boundaries: the legal Voluntary Standard/Annex II cap is now explicitly separated from EFRAG's evolving digital VS/VSME artefacts, and the former WSI authority/applicability-profile candidate is retired because current Pergamum Pulse Core already owns regulatory temporal and applicability semantics. The two bounded implementation candidates that remain are the ESRS 2026 reporting-profile migration and the regime-specific supplier request-entitlement gate.

W41 authoritative source register

All entries below were rechecked 2026-10-06.

Event	Authoritative source	Authority use
Revised ESRS	EUR-Lex — Delegated Regulation (EU) 2026/1563	OJ publication, 10.11.2026 entry into force, FY2026 transition and FY2027 application.
Voluntary Standard	EUR-Lex — Delegated Regulation (EU) 2026/1560	Legal standard and Annex II/value-chain-cap authority.
EEA status	EFTA — 32026R1563; EFTA — 32026R1560	Both remain under scrutiny for EEA incorporation.
Revised ESRS datapoints	EFRAG — 2026 Draft List of Datapoints	Support material; fatal-flaw process to 23.10.2026.
Revised ESRS XBRL	EFRAG — draft taxonomy consultation	Draft technical taxonomy; consultation to 11.11.2026.
VS guidance / digital tooling	EFRAG — adoption and updated guidance; EFRAG — VSME/VS digital template and XBRL	Non-mandatory guidance; replacement digital package scheduled Q4 2026; legacy packages marked outdated.
CSDDD	European Commission — Corporate sustainability due diligence; EUR-Lex — Directive (EU) 2026/470	Current legal/application/guidance timetable.
PEF	European Commission — EF methods; transitional dataset guidance	Current method baseline and fallback guidance.
Taxonomy disclosures	ESMA — KPI consultation; Platform on Sustainable Finance brief	Technical-advice stage; no binding KPI change.
EmpCo	EUR-Lex — Directive (EU) 2024/825; European Commission — Sustainable consumption	Binding consumer-law baseline and support material.