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The European Sustainable Investment Forum (Eurosif) is urging the European Commission to maintain the high level of ambition reflected in the European Sustainability Reporting Standards (ESRS). The organization believes this does not meet the ambitious goals of the European Financial Reporting Advisory Group (EFRAG) proposal published in November 2022.


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On Friday, June 9 the European Commission published a draft delegated act outlining the first set of European Sustainability Reporting Standards (ESRS). The Commission has thus responded to the requirements of the Corporate Sustainability Reporting Directive (CSRD) adopted in December 2022.  

However, the European Sustainable Investment Forum (Eurosif) has expressed concerns about this. The organization is concerned about the inclusion of a materiality test , as this would allow companies to exclude entire sections of their sustainability disclosures. As such this approach would contradicts EFRAG’s recommendation that these disclosures should always be considered material. This would undermine efforts to address data gaps and enhance the quality and comparability of sustainability disclosures. 

If adopted in its current form, the draft Delegated Act would weaken the effectiveness of the CSRD and the EU sustainable finance framework. Ultimately, Investors and financial market participants rely on reliable and comparable sustainability-related disclosures to make informed investment decisions and comply with regulatory requirements. Moreover, the Act’s requirement for a materiality assessment for important climate disclosures, such as greenhouse gas emissions, climate targets, and transition plans, contradicts the European Commission’s commitment to the goals of the European Green Deal and EU Climate Law. 

The voluntary nature of certain disclosures is also questioned, such as explaining why a sustainability topic is not considered material, as well as disclosures related to biodiversity and a company’s own workforce. The organization emphasizes the need for the European Commission to reconsider its changes and adhere to the final EFRAG recommendations. After all, these would be the result of a compromise among preparers, financial market participants, investors, and civil society. 

In summary, Eurosif calls on the European Commission to: 

  1. Maintain mandatory climate disclosure indicators and topics, including greenhouse gas emissions, climate targets, and transition plans.
  2. Preserve mandatory environmental and social disclosures required for compliance with regulations such as the Sustainable Finance Disclosure Regulation (SFDR), Benchmark Regulation, Climate Benchmark Delegated Acts, and Pillar 3 disclosure requirements.
  3. Reconsider the voluntary nature of specific disclosures, including explanations for why a sustainability topic is not considered material, as well as disclosures concerning biodiversity and a company’s own workforce.

The cleversoft RegWatch team will keep an eye on developments in this regard and inform you of any consequences that may follow. If you have any questions about ESRS or ESG reporting, feel free to contact us at any time.