Small and medium-sized companies will remain exempt from new disclosure rules on the EU’s sustainable finance taxonomy starting in 2022. However corporate leaders would be well-advised to follow its implications, including SMEs, writes Finn Wendland.
Finn Wendland is an economist specialised in climate and energy policy at the German Economic Institute.
The EU taxonomy raises the sustainability disclosure requirements for
large public-interest companies as of January 2022, yet small and
medium-sized companies (SMEs) will be spared from the new rules until
2026.
Despite the formal exemption, chances are that large investors and
end-producers will pass through their reporting requirements to
intermediate producers regardless – many of whom are SMEs – with the aim
of ensuring taxonomy alignment.
In this context, the recent initiatives from big manufacturers, such
as Porsche or Siemens, to set their own carbon neutrality goals for
their supply chains can be seen as prominent examples in a much wider
trend for more transparency in traditional industry sectors.
The EU taxonomy and related regulations contribute to the growing
top-down pressure for intermediate producers and SMEs to prepare
standardised sustainability information. As only one out of three
companies in Germany has implemented a sustainability strategy,
according to a survey from Commerzbank (2021), it appears reasonable to suspect that few companies are actually prepared.
With the EU taxonomy entering into force, the ability to report in
line with the technical screening criteria – and, ideally, prove a high
share of taxonomy alignment – is likely to be rewarded both from a
regulatory and business perspective. Rather than waiting in passiveness,
SMEs should seize the current situation as a first-mover opportunity to
prepare for the looming reporting requirements on the EU taxonomy and
to build competitive advantages ahead of the green transformation.
Preparing for informational readiness in advance can strengthen SMEs’
positioning to improve business resilience, financing conditions and
sales prospects.
To recapitulate, the EU has adopted the EU taxonomy in 2020 as the
lead instrument to promote transparency on the sustainability
performance of economic activities in Europe and beyond.
By introducing quantitative reporting requirements for listed
companies with more than 500 employees from January 2022, the EU
taxonomy represents a binding precedent among numerous voluntary
eco-labels and standards.
The European Commission plans to extend the EU taxonomy to six
environmental objectives and rules for about 50,000 companies by 2026.
Relevant disclosure information includes the shares of turnover, capital
expenditure (CapEx) and operational expenditure (OpEx) that can
justifiably be linked to ecologically sustainable activities.
Given the ambitious thresholds to be reached under the screening
criteria, the EU taxonomy is viewed by some as the new gold standard to
certify the greenness of business models and investments.
Although the new mandatory disclosure rules are limited to large
market participants first, there is reason to believe that SMEs may feel
its consequences both at a larger scale and earlier than expected. The
apparent lack of preparedness and discussion on possible taxonomy
implications among SMEs in intermediate producing sectors seems
especially surprising given the different financial and economic
dependencies with large stakeholders.
In particular, the growing importance of financial transparency for
investors and the new regulatory incentives for end producers hint
towards two potential lines of conflict.
First, as sustainability has become a main concern for politicians
and consumers, numerous investors have raised their commitments on
sustainable project finance. In 2019, the European Investment Bank, the
EU’s central infrastructure and development bank, announced to raise its
share of sustainability-compatible investments to at least 50% by 2025.
Principally, the new interest in green finance among creditors well
coincides with the growing demand from companies to fuel their
investment needs for carbon-neutral technologies and innovation. The
European Commission plans to embed the EU taxonomy at the heart of
financial instruments, credit ratings and banking rules in the aim of
easing the sustainable finance conditions.
As the EU taxonomy seems bound to become the key selection tool for
sustainable finance across the EU, it may also turn out critical for the
potential blacklisting of investments without a minimum degree of
compliance. In this context, preparing sustainability documentation in
line with the EU taxonomy from early on can help SMEs to avoid excess
financing costs and gain investors’ confidence.
Second, as the first batch of the EU taxonomy’s screening criteria
focuses on activities in energy-intensive intermediate sectors, such as
power generation and manufacturing, its implications are likely to
affect supply chains and supplier-producer relationships at a wider
range.
Under Article 8 of the EU taxonomy, companies can credit parts of
their turnover and OpEx derived from taxonomy-aligned input for their
environmental performance, leaving final producers with an inherent
interest to ensure full taxonomy-alignment of their supply chains.
As the degree of taxonomy-alignment becomes a supplier selection
criterium in the future, SMEs in intermediate sectors which can prove
their taxonomy-compliance put themselves in a potentially advantageous
position vis-à-vis competitors.
Recent initiatives from Daimler and Volvo to involve in long-term
partnerships with prospective green steel producers (H2GS and SSAB) hint
towards a keen interest by manufacturers in traditional industries to
address key emissions sources and to restructure their supply chains in
response to the environmental challenges.
To sum up, while numerous companies stay exempt from the new
disclosure rules on the EU taxonomy as of 2022, corporate leaders and
managers are well-advised to follow its implications as industry leaders
and market structures reorganise to address the long-term environmental
objectives.
Further, SMEs can carve out competitive advantages to strengthen
business resilience, improve financing conditions and promote sales
prospects by dealing with the EU taxonomy and preparing for
informational readiness from early on.
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