Response submitted to the European Commission on revised ESRS

On 6 May, the European Commission (EC) published the draft delegated act (DA) to adopt simplified European Sustainability Reporting Standards (ESRS), following a long revision process. At the same time they issues a public request for feedback before these revised ESRS are officially issued. 

Details of proposed changes

European Commission publishes updated draft version of revised ESRS

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In our feedback, we have communicated that we are pleased to see this revision project coming to its conclusion as it will give much needed certainty to reporting entities preparing sustainability disclosures using ESRS and allow them to invest in preparing high quality reporting. However, we do still have a number of concerns, primarily in the following areas:

• Interoperability with the IFRS Sustainability Disclosure Standards (SDS) - we believe that there are a number of areas in which the revised ESRS drop below the global baseline established by the IFRS SDS. We also recommend that the EC should, as a priority, prepare and publish formal interoperability mapping between the ESRS and IFRS SDS.
• Fair presentation and the double materiality assessment - we note that applying the fair presentation concept to the assessment of impact materiality is unique to ESRS. We recommend a number of points of clarification or additional guidance to enable consistent application of these concepts.

You can read our full response by clicking here.

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