Réponse de l’AFG à la consultation de la Commission Européenne sur les standards extra-financiers (ESRS)

On June 9 2023, the EC issued a consultation on its proposed Delegated Regulation on the CSRD to incorporate ESRS. The AFG responded on 7 July 2023, expressing support for the EC’s efforts in establishing an effective sustainability reporting framework. AFG also welcomed the adjustments to the ESRS aimed at reducing information requirements to ease administrative burdens and improve reporting readability.
However, AFG raised significant concerns regarding the differentiated treatment of corporates and financial institutions, particularly regarding the materiality assessment of PAI indicators. AFG emphasized the importance of reconciling SFDR PAI indicators and ESRS requirements to enable financial institutions to meet their regulatory obligations without data gaps. The current inconsistency between the frameworks may lead to increased dependency on data providers and additional burden on issuers.
AFG urged the EC to reconsider its position and treat PAI indicators (mandatory and additional) as always material for financial institutions. If the EC maintains the materiality assessment, it should be consistent throughout the SFDR, and any materiality determination must be justified.
Additionally, AFG expressed regret over several changes made by the EC, such as insufficient guidance on defining „material“ indicators, conversion of some mandatory requirements to voluntary ones, reduced information granularity, and a higher threshold for the additional phase-in period.
Climate reporting’s role in achieving global climate objectives was highlighted, and AFG called for the removal of materiality assessments for climate transition plans and targets, ensuring comparability among undertakings. They advocated for making the required information on biodiversity and ecosystems in strategy and business models mandatory again.
AFG emphasized the need for new social PAI indicators proposed by the ESAs to be included in the ESRS and made mandatory once the CSRD disclosure requirements are applicable. Interoperability between reporting frameworks, such as ISSB, SEC, and GRI, was deemed crucial to improve consistency, comparability, and reliability of sustainability reporting and reduce operational burdens for undertakings reporting under the future ESRS.