Our response to the consultation on the amended European Sustainability Reporting Standards (ESRS) reflects both recognition of progress and concerns about what is still missing for individual investors. We welcome the efforts to simplify the regulatory framework.
Reducing unnecessary datapoints and avoiding excessive box-ticking can indeed lower the burden on EU businesses. But simplification should not come at the expense of EU individual investors, who also face constraints: they depend on clear, comparable and accessible sustainability information to make informed decisions about where their savings and pensions are invested. If disclosures become shorter but less consistent, the real burden shifts from companies to citizens, who will have to guess what is missing.
For individual investors, the key issue is intelligibility and comparability of non-financial reporting. Retail savers do not build complex models; they need a minimum set of stable, clearly presented indicators on governance, climate, workforce, and business conduct. Simplification has often been achieved by removing precisely these guardrails.
For example, requirements to disclose whether companies plan to adopt sustainability targets, or to report on workforce fatalities and board sustainability expertise, have been deleted or downgraded. We therefore hope that EFRAG will take our position and views into account when finalising the standards later this year, so that simplification benefits both businesses and individual investors, and the Green Deal’s objectives can be met in practice.
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