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15 July 2022

ESMA: ISSB’s Exposure Drafts ‘IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information’ and ‘IFRS S2 Clim


... we have observed in the past years the growing interest by financial market participants ... in morerelevant, reliable and comparable disclosures relating to ESG factors (... ‘non-financial information’ or ‘sustainability reporting’)...

We are pleased to provide you with the following comments with the aim of contributing to the development of a high-quality set of international standards for corporate reporting on matters relating to Environmental, Social and Governance (ESG) aspects.


As part of ESMA’s mandate to consider sustainable business models and ESG-related factors
across the different areas of legislation within our remit, we have observed in the past years
the growing interest by financial market participants, as well as by other stakeholders in more
relevant, reliable and comparable disclosures relating to ESG factors (hereinafter referred to
as ‘non-financial information’ or ‘sustainability reporting’).


European legislation in the area of sustainable finance has given further stimulus to the market
demand for sustainability reporting. Subject to the finalisation of the Corporate Sustainability
Reporting Directive (CSRD), steps are underway to set up a comprehensive set of European
Sustainability Reporting Standards (ESRS) that aims at addressing this demand while taking
into account some key specificities of the European context, most notably: the need to cover
the entire spectrum of ESG topics, the importance of the ‘double materiality’ principle and the
need to be consistent with major pieces of sustainable finance legislation, such as the
Taxonomy Regulation, the Regulation on sustainability‐related disclosures in the financial
services sector (also referred to as ‘SFDR’) and the Regulation on indices used as benchmarks
in financial instruments and financial contracts or to measure the performance of investment
funds (also referred to as ‘Benchmarks Regulation’).

much more at  ESMA



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