Posted by Peter Kajüter, on behalf of the EAA Stakeholder Reporting Committee
On 29 April 2022, EFRAG launched a public consultation on 13 Draft EU Sustainability Reporting Standards (ESRS), with a deadline of 8 August 2022. This followed the Corporate Sustainability Reporting Directive (CSRD) proposal, and the letter from Commissioner McGuinness requiring EFRAG to provide Technical Advice to the European Commission in the form of fully prepared draft standards and/or draft amendments to ESRS. These EDs correspond to the first set of standards required under the CSRD proposal and cover the full range of sustainability matters: environment, social, governance and cross-cutting standards.
The Stakeholder Reporting Committee focused their comments in the cross-cutting standards, Exposure Draft ESRS 1 General principles Exposure Draft ESRS 2 General, strategy, governance and materiality assessment disclosure requirements. The letter is attached to this blog..
Our comments were mainly oriented towards the need to clarify the text of the EDs. Thus, we highlighted the convenience to have more consistency in terminology and avoid the use of words with several meanings. We also required more clarity about the rebuttable presumption, and about the materiality assessment. And we questioned the convenience to define the three horizons of analysis at sector–agnostic level.