The Dutch Fund and Asset Management Association (DUFAS) welcomes the opportunity to respond to the EFRAG Survey on the Amended ESRS Exposure Drafts 2025, to which we have submitted our input today. Representing the asset management sector in the Netherlands, our response signals support for EFRAG’s efforts to simplify the European Sustainability Reporting Standards, as well as for important proposals such as in the areas of fair presentation and (reliefs for) anticipated financial effects. However, in our response we also highlight a few areas where we feel the decision usefulness of reporting requirements still needs further improvement.
Alignment of ESRS with investor needs
As a central building block of the EU Sustainable Finance Framework, the CSRD and its accompanying reporting standards are crucial to the ability of the financial sector to contribute to the EU policy objectives of helping improve the flow of capital towards financing the transition to a sustainable economy. In our response to the survey, we address a few issues where the alignment of the significantly reduced reporting standards with investor needs can still be improved, while maintaining coverage of the most critically relevant datapoints. This concerns, for example, alignment with the SFDR. Notwithstanding the upcoming SFDR review, we ask EFRAG to ensure that within the ESRS all datapoints corresponding to the 14 mandatory PAIs are retained. These indicators are essential for the functioning of the SFDR and must remain fully available to financial institutions. Additionally, we also propose maintaining one methodology for both actual and potential
impacts, rather than a ‘hybrid’ approach. Lastly, we argue that the decision usefulness of various social indicators are negatively impacted by the proposed amendments, amongst others on non-EU adequate wages and on the gender pay gap. We kindly refer to our full response for further details on these, and other, issues.
Value chain of financial institutions
In the consultation document, EFRAG indicates that the value chain of financial institutions for purposes of CSRD reporting is subject to level 1 changes. In this light, we reiterate our position that client assets should be explicitly excluded for purposes of CSRD reporting, as asset managers do not own these assets they manage. We argue that sustainability-related requirements for financial products and services should be covered by targeted financial sector legislation that is fully aligned with requirements focused on corporate disclosures. We therefore repeat our call to the European legislator to confirm that under CSRD, in addition to UCITS and AIFs (“collective management”), also mandates/managed portfolios
(“individual mandates”) are out of scope for purposes of mandatory reporting. This eliminates reporting and administrative overlap for the financial sector.
Dependence on third-party data providers expected to increase
Similarly, even when the ESRS are amended to ensure quality sustainability reporting while reducing administrative burden for reporting companies, a reduced scope of companies reporting under the CSRD will negatively affect data availability for the financial sector. This, in turn, has a negative effect on the ability of the sector to apply this information to investment decision making. To fill this gap, the dependence of asset managers on thirdparty data providers, which are currently not subject to standardized transparency requirements, is expected to increase. We therefore underline the importance of also bringing ESG data vendors within the regulatory perimeter in order to safeguard a minimum level of uniform transparency requirements.
