09 August 2022

EBF Responses to EFRAG consultation surveys

The EBF supports EFRAG’s extensive efforts to build European sustainability reporting standards (ESRS) reflecting the EU’s ambition in tackling sustainability issues. Improving the quantity, quality, and reliability of sustainability disclosures in the EU will only be possible in the presence of efficient and harmonised reporting standards.

To this end, the EBF welcomes the opportunity to provide feedback to the EFRAG’s public consultation through which we both highlight our support for many aspects and propose further improvements in some areas. In particular,

• The EBF welcomes the integration of the concept of double materiality, but also recognises that further guidance will be needed on how to conduct materiality assessments, which will represent an important challenge in the initial phases of reporting
• Sustainability reports will prove to be a fundamental tool for a wide range of stakeholders, including investors and lenders, but will need to focus on data that is useful and relevant while ensuring that such data is easily identifiable for the users of the reports
• Supporting smaller players, and especially non-listed SMEs will be crucial as they will not be obliged to report, but inevitably be affected by the complex reporting framework. In this respect, a voluntary reporting standard providing a simplified format for these players will foster harmonisation and reduce the burden for entities which are not accustomed to sustainability reporting nor have the necessary resources
• We invite the EFRAG to consider the specificities of the financial sector, which relies on the disclosures of its clients for its own sustainability reporting. In this respect, it should be considered that a one-year time lag between the reporting of non-financial entities and financial entities may provide an adequate solution
• Maintaining a co-building approach between the EFRAG and ISSB will be crucial to ensure that that the final ESRS will be interoperable with the ISSB global baseline, avoiding any double reporting

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