In its Position Paper, the AMF has responded to the EC’s draft delegated act on ESRS. The AMF supports this work in developing the ESRS standards, yet raises several important considerations for the European Commission regarding the ESRS standards.
Indeed, the AMF supports the ESRS as a step towards a robust sustainability framework for companies. It emphasizes the importance of proper materiality assessment and avoiding a „check-list“ compliance approach. The AMF suggests clarifying the process of identification of material impacts and risks and requiring the disclosure of non-material conclusions for climate topics.
It calls for a transparent and collaborative governance mechanism involving preparers, investors, assurance providers, and regulators.
The AMF welcomes changes to definitions and concepts in climate standards and advocates for a permanent mechanism for interpreting standards.
It AMF suggests considering the creation of a „transition resource or implementation group“ to support the implementation of the standards. It emphasizes the importance of high-quality sustainability-related assurance standards and diligence to build confidence in sustainability information.
Furthermore, the AMF appreciates the phase-in and optionality measures provided by the European Commission. It emphasizes the need for consistency between European legislations and the data needs of financial market participants, as well as the need for consistency between ESRS and the future directive on corporate sustainability due diligence.
Finally, the AMF hopes that the new disclosure framework will support companies in their transition to a more sustainable economy. It recognizes the role of assurance providers and auditors in ensuring the quality of sustainability information. The AMF commends the interoperability efforts between EFRAG, the European Commission, and the ISSB.
