We also welcome the Commission’s efforts to improve interoperability with international sustainability reporting standards, particularly the IFRS standards, and encourage further alignment where possible. Specifically, we believe climate scenario analysis should be a mandatory disclosure for companies that identify climate change as a material topic, as this information is essential for investors to assess business resilience and long-term climate-related risks.
Furthermore, we support the retention of quantitative disclosures on anticipated financial effects but are concerned that extensive transitional provisions could delay the availability of decision-useful information for investors. We also underline the importance of a high threshold for the omission of material information and greater transparency from companies relying on reporting exemptions.
Finally, we support maintaining alignment with established international frameworks in the social standards, most importantly by retaining the proposed disclosure requirements on adequate wages, while recommending targeted improvements to enhance the consistency, comparability and decision-usefulness of sustainability reporting for investors.’
As DUFAS we welcome the European Commission’s proposed revision of the European Sustainability Reporting Standards (ESRS), which strike an appropriate balance between simplifying reporting requirements and preserving the core principle of double materiality. In particular, we strongly support the clarification that investments managed on behalf of clients are outside the scope of mandatory ESRS reporting. This clarification provides much-needed legal certainty for the asset management industry.
