Sustainable Finance

Governed by the integration rule document. Core scope: EU Taxonomy and its delegated acts, and SFDR. This domain captures investor/lender demand for sustainability evidence while keeping financial-product classification distinct from corporate reporting.

2026-W38 authority register

ID	Finding	Authority / disposition
SF-01	EU Taxonomy remains an existing binding regime; no new wholesale replacement was identified in this cohort.	LEGAL_ACT; baseline.
SF-02	ESMA's selected-KPI simplification work covers OpEx and mixed-group reporting; final technical advice is expected by end-October 2026.	PROPOSAL/technical advice; WATCH, no binding KPI change yet.
SF-03	Parliament's SFDR procedure records the 10 September committee vote/report and decision to open interinstitutional negotiations.	PROPOSAL, negotiation stage; AWAIT_AUTHORITY.

Architecture Integration decision

No new binding finance rule in 2026-W38 justifies a production migration.

The architecture should continue to preserve independent objects/versions for:

• activity eligibility;
• substantial-contribution criteria;
• DNSH;
• minimum safeguards;
• turnover/CapEx/OpEx attribution methodology;
• financial-product category/profile;
• portfolio exposure;
• PAI definition/evidence;
• transition evidence.

This separation remains important because a future KPI-method change may not alter technical screening criteria, and a future SFDR product-category change must not rewrite enduring product identity or historical disclosures.

Disposition: WATCH / AWAIT_AUTHORITY. No Hecate Need is justified from this cohort alone.

Evidence projection rule

Corporate disclosures may be reused as source evidence only through explicit projections preserving entity, period, perimeter, units, estimation, missingness and the consuming finance definition. Missing evidence is not zero; a corporate aggregate is not automatically a portfolio-weighted value; due-diligence evidence does not automatically satisfy Taxonomy minimum safeguards.

Acceptance criteria

Scenario	Expected behavior
Activity is Taxonomy-eligible	Do not infer alignment without the applicable criteria, DNSH and safeguards tests.
KPI methodology changes in a later delegated act	Recalculate/version KPI methodology without overwriting historical criteria or reports.
SFDR negotiating category changes	Simulate candidate product profile without relabelling live products.
Corporate disclosure supplies a metric with a different perimeter	Require an explicit projection/transformation; do not silently reuse.
PAI evidence is missing	Preserve missingness; never convert to zero by default.

Cross-regime collisions

X-06 — Taxonomy vs SFDR. Eligibility, alignment and product category are separate assertions.

Corporate Disclosure provides reusable source data but not automatic finance compliance. Supply-Chain Due Diligence may provide safeguards evidence but the finance rule owns its sufficiency test. Regulatory Infrastructure owns taxonomy/schema versions, not the economic-activity alignment decision.

Canonical review status

This cycle did not identify enough current finance-specific canonical documentation to justify a new architecture change. Before any Hecate Need:

• locate existing EU Taxonomy/SFDR schemas and computation methods;
• inventory supported delegated-act versions;
• identify portfolio/PAI ownership;
• compare the future ESMA advice and SFDR compromise text against that baseline.

Weekly cohort history

Cohort	Intelligence retained	Integration decision
2026-W36	Taxonomy KPI simplification consultation	WATCH; keep KPI methodology configurable.
2026-W37	No material new binding finance event	NO_ACTION.
2026-W38	SFDR committee event	Integrated 2026-09-15: negotiation signal only; no production category/KPI migration and no Hecate Need. Preserve modular finance evidence architecture pending authoritative text.

What changed in ZAYAZ? Nothing in production. The finance domain remains intentionally staged: current negotiations reinforce modular category/KPI/evidence design but do not yet justify implementation changes.

2026-W39 Architecture Integration

Authority recheck

ID	Finding	Classification / disposition
SF-W39-01	Parliament's SFDR file records the 10 September committee vote/decision to open negotiations and the committee report tabled on 15 September. The file remains in the ordinary legislative procedure.	PROPOSAL; PRODUCT_STRATEGY_DELTA; WATCH / AWAIT_AUTHORITY.
SF-W39-02	The Commission still lists the March 2026 Taxonomy technical-screening-criteria amendments as not yet adopted and not in force.	PROPOSAL; TAXONOMY_CHANGE; AWAIT_AUTHORITY.
SF-W39-03	Existing Taxonomy criteria and the 2026/73 disclosure simplification remain the active legal baseline unless a later adopted act changes them.	LEGAL_ACT; NO_ACTION beyond versioned baseline maintenance.

Architecture decision

No production finance-profile change is justified in W39. The current modular design remains correct:

• activity eligibility;
• alignment tests;
• substantial contribution;
• DNSH;
• minimum safeguards;
• KPI methodology;
• SFDR product category;
• PAI evidence;
• transition evidence.

Draft Taxonomy criteria may be staged for impact analysis, but must not overwrite active criteria. Candidate SFDR categories may be modelled for scenario testing, but must not relabel live products.

Acceptance criteria

• Draft Taxonomy TSC changes can be simulated side-by-side with active criteria.
• A draft criterion cannot generate an active alignment result.
• SFDR negotiation-stage categories cannot alter historical product classifications.
• Corporate ESRS datapoint or XBRL changes do not automatically change PAI or Taxonomy semantics; explicit mappings remain required.

W39 history

What changed in ZAYAZ? No finance production behavior changed. W39 confirms that both SFDR reform and the broader 2026 Taxonomy TSC revision remain staged candidate profiles only.

W39 source/evidence register

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

Event	Authoritative source	Locator
SF-W39-01	European Parliament — SFDR procedure 2025/0361(COD)	Committee vote/opening-negotiations event and committee report tabled in September 2026; ordinary legislative procedure remains pending.
SF-W39-02	European Commission — Taxonomy delegated acts	17.03.2026 draft TSC amendments identified as not yet adopted and not in force.
SF-W39-03	European Commission — Taxonomy delegated acts	Commission Delegated Regulation (EU) 2026/73 published 08.01.2026; active baseline unless superseded.