Reform of the EU Non-Financial Reporting Directive
1. SCOPE. Expand the scope of the EU Non-Financial Reporting Directive so as to cover:
- All public interest companies, irrespective of their size, including non EU companies which securities are admitted to trading in the EU...
- All large companies as defined in the Accounting Directive...
- All small and medium-sized companies whose business activities are linked to significant impacts...
- Financial market participants...
2. ALIGNMENT WITH THE ANNUAL REPORT
- Ensure that the non-financial statement is made available together with the annual report
3. DOUBLE-MATERIALITY: Clarify the double-materiality definition and principles based on the following:
- undertakings should consider which information is relevant from the perspective of their economic, social and environmental dependencies [...] and from the perspective of understanding their impact on people and the environment
- Materiality from the ‘impact’ perspective means information about severe actual negative impacts and potential negative impacts on people and/or the environment
4. GOVERNANCE AND ACCOUNTABILITY: Integrate reporting requirements covering the issues of governance and accountability for sustainability matters:
- Introduce a requirement mandating undertakings to describe the board’s oversight of and management’s role in assessing and managing of non-financial risks and opportunities...
- Introduce a requirement mandating undertakings to report on the integration of the non-financial risks, impacts, opportunities, policies and targets...
- Provide a mandate to the EU standard setter to develop an appropriate standard for reporting on integration of thematic information...
5. GENERAL REPORTING REQUIREMENTS: For each issue reported on, based on the application of the double materiality principle and the thematic requirements and corresponding EU reporting standards (see Section 6), disclosures should include a description of: ...
- company business model...
- Material risks and opportunities facing the company arising from each issue and how these are included into the company’s risk management process...
- The most significant actual impacts and risks of such impacts on people and the environment, alongside an indication of where in the value chain...
- The strategy put in place by the company to address the identified impacts, risks and opportunities, including actions taken...
- Targets or objectives and timelines for achieving them [...] and performance against those targets, including KPIs...
- Information required by the EU taxonomy...
- Information outlined in specific reporting requirements and corresponding EU reporting standards...
6. THEMATIC REPORTING REQUIREMENTS: In addition to the information requirements in Section 5 above, undertakings should report the thematic information specified below...
- Climate...
- Natural resources, biodiversity and ecosystems...
- Workforce and human rights matters...
- Anti-corruption...
7. ASSURANCE
- Non-financial assurance should be subject to mandatory assurance...