Réponse de l’AFG à la consultation de la Commission Européenne sur les 4 derniers objectifs de la Taxonomie

The AFG published an opinion to the European Commission consultation on the Environmental Taxonomy which aims to finance a more sustainable economy.
The AFG supports legislative and regulatory initiatives to ensure greater transparency and achieve the EU Green Deal objective to reorient capital towards sustainable finance. The AFG believes that it is essential to align CSRD and Taxonomy application timelines to ensure a consistent and orderly application. However, AFG highlights concerns with regards to the application timeline proposed for non-financial undertakings, as stated in Article 5 of the proposal amending article 10 of the Delegated Regulation. The proposal mandates non-financial undertakings to report on eligibility from 1 January 2024 and alignment from 1 January 2025. The AFG believes that this application timeline is too optimistic and may raise some operational issues.
The European Commission’s consultation was open until 3 May 2023, and the publication and translations in the Official Journal of the European Union may also take some time. After the official publication, non-financial undertakings will need some time to gather the data and to understand and implement these new ambitious criteria. It is hence difficult to ask non-financial undertakings to disclose eligibility and alignment from 1 January 2024 and 1 January 2025, respectively, on elements that will be available in late 2023.
The AFG recommends that the European Commission grant a one-year delay on the application of this first disclosure, meaning non-financial undertakings should disclose eligibility from January 2025 and alignment from January 2026.
The AFG welcomes the European Commission Proposal to replicate the one-year delay approach that was granted for the first two objectives of the EU Taxonomy for financial undertakings. AFG believes that this one-year delay between the KPI publication of non-financial undertakings and the KPI publication of financial undertakings should remain. Financial undertakings depend on their counterparts’ reporting. Following the one-year delay asked for the non-financial undertakings, financial undertakings would disclose alignment from January 2027.
In the context where the CSRD ambition may be lowered, and the application calendar may be delayed, the AFG believes that the a one-year delay is crucial for financial undertakings to align with the new ambitious criteria proposed by the Taxonomy.