ESBG submitted its response to the European Financial Reporting Advisory Group (EFRAG) public consultation on the first set of Draft EU Sustainability Reporting Standards (ESRSs) on 4 August. The consultation comes in response the European Commission’s proposal for a Corporate Sustainability Reporting Directive (CSRD) which envisages the adoption of EU Sustainability Reporting Standards (ESRSs). As part of this, the Commission mandated EFRAG to provide technical advice in the form of draft sustainability reporting standards.
In its response, ESBG highlighted the need for consistency between the International Sustainability Standards (ISSB) sustainability disclosures and the EFRAG ESRSs in order to ensure a levelled global playing field. Moreover, ESBG emphasises the lack of proportionality with respect to disclosure requirements, specifically for smaller/unlisted companies and proposes the provision of certain reporting requirements being made optional.
With respect to implementation challenges, ESBG considers that the data availability issue is the most critical challenge for financial institutions. Taking into consideration the above, ESBG proposed two phase-in solutions that are mutually complementary: i) first year reporting on own operations and gradual reporting on information from the value chain and ii) prioritisation of climate topics and gradual consideration of other environmental, social and governance topics.
Furthermore, we believe that there is not enough guidance in the exposure drafts with respect to the application of the double materiality principle (the requirements for companies to disclose not only the risks that affect, but also their impacts on society and on the environment). In this sense, this concept needs to be clarified and more guidance is needed in relation to specific sectors in due time.
ESBG stresses the limitation on disclosing value chain information for companies. We consider it is difficult to obtain information from companies that are not under the control of the institution (e.g. associate companies). We propose that a phase-in period of 2 years must be granted to financial undertakings to allow them to adapt their processes to collect the necessary information from their value chain.
As a next step, ESBG will evaluate if there is interest from members in submitting input into the up-coming EFRAG consultations on SME specific standards as well as on sector specific standards (EFRAG consultations are expected to be published in 2023).
related
May 4, 2023
ESBG responds to the Commission’s consultation on its Taxonomy Environmental Delegated Act
On 3 May, ESBG responded to the Commission’s consultation on its new set of EU taxonomy criteria for economic activities that
April 12, 2023
ESBG revises its position paper on the CSDDD in accordance with the recent negotiations
Given the developments of the recent political negotiations, ESBG has decided to update its position paper on the Corporate Sustainability Due Diligence Directive (CSDDD)
February 21, 2023
ESBG responded to the ESMA consultation about the use of ESG terms in funds’ names
On 17 February, ESBG submitted its response to the ESMA consultation about the use of ESG terms in funds’ names
February 3, 2023
Advocating on the EU deforestation regulation
What lessons can be learnt from a French diplomat from the XIX century?
January 11, 2023
ESBG responds to the ESAs call for evidence on greenwashing
Therefore, in the interest of customers, banks, saving banks and issuers of financial products, ESBG
October 5, 2022
Joint letter to Commissioner McGuinness on the EFRAG consultation regarding its first set of draft ESRSs
On 27 September, the ESBG, together with the European Banking Federation (EBF), the European Association of Co-operative Banks (EACB), Insurance Europe, Accountancy Europe, Business Europe and…
September 7, 2022
EU Taxonomy minimum safeguards: Criteria for the application of external checks should be further defined
The European Savings and Retail Banking Group submitted its final response to the Platform for Sustainable Finance (PSF) consultation on its draft report on minimum safeguards (MS). In its response,…
August 3, 2022
International Sustainability Standards Board consultation on Sustainability Disclosures
The International Sustainability Standards Board (ISSB) has been established at COP26 with the purpose of developing a comprehensive global baseline of sustainability disclosures for the capital…
July 8, 2022
World savings and retail banks call for harmonised taxonomies on sustainable finance
The World Savings and Retail Banking Institute (WSBI) called today on policymakers for the harmonisation of taxonomies on sustainable finance. At the end of the 26th WSBI World Congress, the…
July 7, 2022
World savings and retail banks moving forward on sustainability
World Savings and Retail Banking Institute (WSBI)'s members get together for the first time since 2018 at the 26th World Congress, in Paris. Under the title 'Locally Rooted, Globally responsible' the…