Date: 17th June 2023

BETTER FINANCE, as an independent financial expertise center serving European financial services users, represents millions of individual investors in Europe who stand to benefit from the draft non-financial reporting Standards developed by EFRAG. BETTER FINANCE welcomes the opportunity to provide feedback on the draft Delegated Act (DA) by the European Commission concerning the European Sustainability Reporting Standards (ESRS).

Investors, including individuals, require not just more data on climate and sustainability risks and opportunities, but also improved, comparable, and understandable data to assess the risks and opportunities faced by companies. Conversely, companies face an increasing need to provide comprehensive and detailed reporting on their material non-financial sustainability information. The requirements for sustainability reporting for companies are diverse, including ESRS, CSDR, Taxonomy, and MiFID sustainability preferences.

Considering our initial responses to EFRAG's consultation on ESRS and the final draft, which saw a significant reduction in disclosures, BETTER FINANCE believes that the European Commission should not further diminish the ambition of ESRS. At the very least, there should be a set of mandatory disclosure requirements (such as GHG emissions) irrespective of materiality assessments made by companies.