13 February 2024

EBF response to the EFRAG ESRS Implementation Guidance consultation

EBF welcomes EFRAG’s development of the ESRS implementation guidance considering ..significant complexity ..importance of for preparation of comparable and qualitative disclosures...timely elaboration of specific guidance for financial institutions would be equally important and necessary

General Comments
The European Banking Federation (EBF) welcomes EFRAG’s development of the ESRS
implementation guidance considering the significant complexity of the standards and the
importance of ensuring the preparation of comparable and qualitative disclosures. The
future and timely elaboration of specific guidance for financial institutions would be equally
important and necessary given the fundamental role they have in financing the global
economy.
Although EFRAG states that it “plans to work on the development of further draft standards
or guidelines for Financial Institutions and on that occasion, specific solutions will be
consulted on for comments”1, it is currently unclear when such clarification will be
developed and available. The lack of specific guidance leaves a series of questions on key
concepts introduced by the ESRS unanswered, although the implementation phase has
already been initiated. While a 3-year phase-in is foreseen for value chain reporting, we
expect that a specific standard for banks that provides clarification will be published by
EFRAG in the future.
Furthermore, it would be appreciated that EFRAG continue its work with the ISSB in the
development of guidelines to ensure alignment to the level that the ISSB standards can
be applied by internationally operating financial institutions as a global baseline for
sustainability reporting....

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