BETTER FINANCE welcomes the substantial simplification already achieved through EFRAG’s revised ESRS and supports efforts to reduce disproportionate reporting burdens. BETTER FINANCE also welcomes the retention of important principles including fair presentation and double materiality. However, several additional amendments introduced by the Commission may have broader implications for transparency, comparability and the usefulness of sustainability information relied upon by investors and financial services users.
BETTER FINANCE particularly wishes to highlight:
- financial institution exemptions;
- cumulative effects of reliefs and phase-ins;
- comparability risks arising from methodological flexibility;
BETTER FINANCE therefore encourages the Commission to further assess whether the cumulative effects of EFRAG’s datapoint reductions combined with additional exemptions, reliefs, phase-ins and methodological flexibilities introduced by the Commission may unintentionally reduce the comparability, consistency and decision-usefulness of sustainability information. Particular consideration should be given to areas relating to asset management-related exemptions, as information increasingly relied upon by investors and end users.
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