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We broadly agree with the CP’s proposals on the due process procedures to be followed by EFRAG in its role as technical advisor to the European Commission (EC) in developing draft European
Sustainability Reporting Standards (ESRS) or draft amendments of ESRS.
However, we provide some comments for further consideration as per the sections below.
Chapter 1: Objective A transparent and inclusive due process every step of the way
(1) Accountancy Europe supports EFRAG’s proposals in paragraph 1.6 of the CP on adopting a due
process composed of core and additional steps: the core and mandatory steps outlined in paragraph
5.1 of the CP and the additional ones in paragraph 5.2. of the CP. The possibility to apply an
accelerated due process fits the urgency and rapidly changing priorities on many sustainability topics,
whilst always ensuring robustness of the due process.
(2) Whilst paragraphs 5.3 and 3.10 of the CP predict cases where the mandatory steps of the due process may not be met, we suggest these deviations be rare and one-off cases. In such cases, these
deviations and the new proposed process should be approved by the Administrative Board upon the
advice of the Due Process Committee (DPC) to ensure that the principles of the due process are met
either way.
(3) We cannot emphasise enough the need to:
a. ensure transparency in all the steps of developing ESRS or draft amendments of the
ESRS, as well as
b. allowing for an adequate public consultation period with stakeholders (not less than
60 days as provided in paragraph 5.1.b) of this CP).