They will power the EU’s under-revision
Non-Financial Reporting Directive,
and improve the relevance, completeness, and decision-usefulness of the
data companies report by law. The first disclosures using the standards
shall be filed in 2023.
Better data can drive and track progress against the European Green Deal
Better corporate data is urgently needed to transition the European economy from its current 2.7 °C path onto a Paris-aligned pathway, and to achieve the European Green Deal.
CDP Europe’s latest report,
for example, found just 35% of the most impactful European companies
report their most important Scope 3 emissions, like use of products.
More accurate emissions data - and information on companies’
trajectories – is needed to hit the EU’s 2030 and 2050 goals.
But
without better standards, this data will not be available quickly
enough for the urgent transformation we need to take place.
The much-anticipated publication of the EFRAG task force’s final report
– a roadmap of recommendations for the standards’ ‘scope and
structure’– is therefore crucial and shows a promising direction of
travel.
Importantly, with the International Financial Reporting Standards (IFRS) having announced
its own approach – covering climate-related financial disclosures – the
EU’s progress will be instrumental not only for corporates with EU
operations, but for raising the bar on global moves to converge
sustainability standards, too. A co-construction approach to align EU
and global standards will help deliver a level playing field for
companies and financial institutions.
A welcome approach
Some
report recommendations, though by no means exclusive, are particularly
welcome and worth highlighting from our perspective.
We strongly welcome the report’s emphasis on forward-looking data. In particular, that the standard-setter should ensure what companies report can produce clear transition trajectories.
This
can be done through guidelines on targets and action plans that are
science-based. 50% of European market value is now engaged with the
Science Based Targets initiative (SBTi), and work for other earth
systems such as fresh water, oceans, land and biodiversity is being
developed by the Science Based Targets network. This approach therefore has significant market momentum and is proven to over-deliver emissions reductions in line with 1.5 °C.
Likewise, we strongly agree with the overarching double materiality approach
suggested for the standards. This means that non-financial reporting
should produce data about the material impacts a company has on its
stakeholders – including the environment – as well as the risks and
opportunities the company sees to its value resulting from
sustainability issues. The 9,600 companies already disclosing
environmental data to CDP are already familiar with disclosing data in
line with this perspective and such an approach is vital for any global
standard.
Another key recommendation is for the standards to treat sustainability information equally to financial data,
as per the Task Force on Climate-related Financial Disclosures (TCFD).
Putting financial and non-financial data on equal footing helps
companies embed sustainability into strategy, makes boards accountable,
and crystallizes the fact that long-term, sustainable business success
relies on environmental sustainability.
We also agree
that, for small and medium-sized enterprises (SMEs), a proportionate
approach is needed. SMEs are a major part of our economy, and EU
environmental goals will not be achieved without them moving in sync
with financial institutions and listed companies. That is why CDP offers
the thousands of SMEs reporting each year the ability to report to
their customers through a simplified questionnaire.
Writing
the new standards with such an approach for SMEs will both help these
companies see the tangible business benefits from reporting, and provide
their stakeholders with the critical data they need to make decisions.
A new era in data
The
EFRAG task force report also suggests that the standard-setter should
promote the structured digitization of sustainability data. We agree.
The European Commission’s vision is for a single European data space – a
single market for data – where live sustainability data sits alongside
financial data and can be more easily employed to achieve EU objectives.
This will help financial institutions of all sizes access vital data
and use it to make decisions that can shift the trillions. The European
Single Access Point, in particular, offers a pathway to achieve this.
CDP’s
disclosure system has and will continue to be a driving force for
scaling such progress. Now with the world’s most comprehensive single
comparable source of environmental data, including nearly 80% of
Europe’s real economy value, CDP can drive structured data disclosure in
line with the standards.
We have long contributed to the EU
sustainable finance agenda, and will continue to support the work of the
European Commission and EFRAG, including in task forces like that on
non-financial risks and opportunities reporting, on which I sit as a member.
By
recognizing that the new standards should both learn from existing best
practices and coordinate with global developments to harmonize
standards, the EU is shifting global ambition and action upwards. It is
welcome that, as the pace quickens, the task force recognizes that a
globally coordinated approach must be pursued.
As the next
stage of this exciting process gets underway, we look forward to
continuing to provide our insights and expertise to the Commission and
the new standard-setter on other key elements in the standards, like
sector- specificity, and with our disclosure system, data, and insights.