The European Fund and Asset Management Association (EFAMA) calls on the European Commission to reflect EFRAG´s recommendations for mandatory European Sustainability Reporting Standards in the upcoming NFRD review.
Currently, the lack of quality data on how companies
perform against sustainability metrics stands out as a
fundamental challenge to leveraging private capital
addressing the European Green Deal funding gap. EFAMA
therefore believes that accelerated development of
mandatory European Sustainability Reporting Standards could
become a game-changer unleashing the impact of sustainable
finance.
EFRAG´s proposals for the standard-setting process
are positive as they:
Recognise the “insufficient
quality of sustainability reporting” and the “specific
challenges financial institutions face in reporting their
sustainability impacts”. By addressing the
inconsistencies between the recently adopted sustainable
finance legislative initiatives, mandatory European Sustainability
Reporting Standards (ESS) can improve the integration of
ESG into investment decisions and support the fulfilment of
asset managers´ own disclosure requirements. For example,
disclosures following the ESS under the revised NFRD would serve as the primary source of input for financial
institutions´ reporting requirements imposed by the EU
Taxonomy KPIs and the SFDR.
Aim to operationalise the
double materiality concept and strengthen the interactions
between impact and financial materiality perspectives.
This link could be supported by the proposed integration of
sustainability statements in management reports.
Recommend improving the quality, availability, and
usability of sustainability reporting “in terms of
reporting structure and presentation”, facilitating its
digitisation. EFAMA
believes that ESS disclosures should be channeled into the
European Single Access Point, which should prioritise the
centralisation of ESG company data on the principle of open
access.
Set strong conceptual guidelines that strike the
right degree of inclusiveness when defining the range of
stakeholders and boundaries of value chain reporting. These
would be complemented by governance duties for corporate
directors under the Sustainable Corporate Governance initiative.
Recognise the need for an urgent solution, and that
the ESS should follow a phased, “climate first approach”,
prioritising disclosures with “advanced standards on
climate change”.
Recommend providing input and contribute to
international standard-setting initiatives in a
“co-constructive” spirit.”
We also find that the information reported under an
ESS can help corporate directors set credible targets and
sustainability objectives, and asset managers perform their
role as stewards of investee companies, contributing to the
objectives of the sustainable corporate governance
initiative.
Dominik Hatiar, Regulatory Policy Advisor, comments:
“If the ESS company
disclosures become available in 2024 [based on the
financial year 2023], financial institutions will still
face a two-year ESG information gap for their own
sustainability reporting obligations under the Taxonomy
green asset ratios and Level 2 SFDR, which apply as of 1
January 2022.
Therefore, the NFRD review needs to be completed as
swiftly as possible”.
“EU´s
sustainability disclosure ecosystem should drive
cooperation towards a globally accepted system by
leveraging alignment with existing, highly relevant
frameworks, such as SASB and TCFD”.
EFAMA believes
that ESS are essential to the achievement of the EU´s Green
Deal objectives and evolving sustainable finance policies,
and at the same time, drive cooperation towards convergence
behind a global sustainability reporting architecture.
EFAMA
© EFAMA - European Fund and Asset Management Association
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