"Joint statement from EFAMA, Eurosif, IIGCC, PRI and UNEP FI on European Sustainability Reporting Standards", 7 July 2023

The European Sustainable Investment Forum (Eurosif), the Principles for Responsible Investment (PRI), the Institutional Investors Group on Climate Change (IIGCC), the European Fund and Asset Management Association (EFAMA), the United Nations Environment Programme Finance Initiative (UNEP FI), as well as 93 undersigned investors and other financial market participants, call on the European Commission to uphold the integrity and ambition of the first set of the European Sustainability Reporting Standards (ESRS), as envisaged within EFRAG’s final technical advice to the Commission published in November 2022.

We welcome the opportunity to provide input on the implementation of the draft Delegated Act. However, we are concerned by the proposals to move away from requiring certain key disclosure indicators to be reported on a mandatory basis, which will instead be subject to materiality assessment. We see this as a significant rollback of ambition compared to that envisaged by the European Financial Reporting Advisory Group (EFRAG). ...

With this in mind, we call on the Commission to:

• Maintain key climate disclosure indicators as mandatory, including Scope 1, 2, and 3 GHG emissions and disclosures enabling investors to assess the credibility of corporate transition plans.
• Ensure that environmental and social indicators relevant to SFDR, EU Climate Benchmark Regulation and Climate Benchmarks Delegated Acts, Pillar 3 disclosures and other investor reporting regulations are disclosed by in-scope companies on a mandatory basis.
• Require explanations as to why certain sustainability topics are not considered material for a company.
• Reconsider the fully optional nature of: (i) own workforce disclosures on non-employees; and (ii) biodiversity transition plans to provide investors with information on how companies will align their strategy and business models in line with the EU Biodiversity Strategy for 2030 and Kunming-Montreal Global Biodiversity Framework.
• Ensure maximum possible interoperability of the ESRS with ISSB and GRI Standards, to reduce fragmentation across the global reporting landscape and support cross-border capital flows while upholding the double materiality principle enshrined in CSRD and ESRS.