17 November 2021

Accountancy Europe: The EU Taxonomy and its Disclosures Delegated Act implementation need clarity

We welcome the European Commission’s continuous commitment to sustainability as the key driverof its agenda. The climate emergency requires urgent action and the transition will require fundamentalchange in policies and business practices.

At Accountancy Europe, we have been long contributing to the sustainability reporting agenda and we
would like to express our support in requiring enterprises to provide targeted information as per the EU
Taxonomy Regulation and its delegated acts. The EU Taxonomy is a fundamental tool to achieve a
truly sustainable economy and to help the entire investment chain build sustainable practices,
underpinned with appropriate reporting thereon.

While the EU Taxonomy Regulation Disclosure Delegated Act supplementing Article 8 aims to provide
further explanation of the reporting requirements, we note that there is a lack of clarity in many aspects
of the practical application of those requirements. The accountancy profession is concerned about the
various interpretations of those requirements. There is a significant risk that we will end up with a
patchwork of interpretations depending on the member state, the sector, or the expert. This will create


confusion and will may further hamper the much-needed global transition. We do not believe that such
information will be valued by investors if it is not comparable and reliable.

Therefore, we would like to emphasise the urgent need to clarify the definitions and the specific
requirements to ensure consistent application of the rules. Implementation and interpretation guidance
is also required urgently. To that end, we call on the Commission to create a formal mechanism in
addition to the EU Platform on Sustainable Finance to deal with interpretation issues. Such formal
mechanism could take the form of an expert group that would be responsible for soliciting, analysing
and solving stakeholder issues arising from the implementation of the requirements. The expert group
could publish, in a structured manner, all questions that arise with a basis for conclusion for the
answers. This expert group could also propose the necessary amendments to the Regulation where
this is necessary for the sake of clarity and consistency.

Full letter

Accountancy Europe

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