Company law: time limits for the adoption of sustainability reporting standards for certain sectors and for certain third-country undertakings

As the Mining Shared Value programme of Engineers Without Borders Canada, we would like to express our concern with the potential delay in implementing sector-specific reporting requirements in the CSRD, and in particular for the extractive industries whose activities disproportionally affect the climate crisis.

EuropeanIssuers represents the interests of publicly quoted companies across 15 European countries, covers markets worth 7.6 trillion market capitalisation, with approximately 8,000 companies. With this regard, EuropeanIssuers welcomes the Proposal for a decision amending Directive 2013/34/EU, concerning the time limits for the adoption of sector-specific sustainability reporting standards.

While welcoming the opportunity to provide feedback on the proposal to postpone the adoption of sector-specific European Sustainability Reporting Standards (ESRS), Bund für Umwelt und Naturschutz Deutschland e.V. (BUND) is deeply concerned about its wider implications. Please find our full response in the document attached.

Following the reform of the EU legal reporting framework and the adoption of sector-agnostic sustainability standards (applicable to companies across all industries), the EU Corporate Sustainability Reporting Directive requires the adoption of complementary sector-specific standards by 2024.

The CorA Network, a network of over 50 non-governmental organisations in Germany, is very concerned about the proposed postponement of sector-specific reporting standards. As reporting on ESG issues became subject to the companies own materiality assessments in the sector-agnostic standards, the uncertainty about what needs to be reported was increased and the comparability of reports diminished.

Fashion is a high-risk sector - The industry is a major driver of the climate crisis and human rights abuses. Fashion companies urgently need to disclose their human rights and environmental risks and impacts in a meaningful, standardised and machine-readable way to enable transparency and corporate accountability.

Eurosif welcomes this consultation and provides a full response in the document attached. Please find below a summary of Eurosifs response: Robust and comparable sustainability-related disclosures are an essential prerequisite to mobilise finance towards the just transition to a net zero economy.

The EU Commission has proposed a two-year postponement in the adoption of the sector-specific European Sustainability Reporting Standards (ESRS). This proposal aims to reduce the reporting burdens on companies and minimise costs, without undermining policy objectives.

SLCP welcomes the opportunity to provide feedback on the proposal to postpone the sector-specific European Sustainability Reporting Standards (ESRS). We are concerned that a delay until 30 June 2026 could be counterproductive for the established objectives.

PwC International Ltd (PwC), on behalf of the PwC network, is pleased to provide feedback on the European Sustainability Reporting Standards (ESRS) - proposed postponement of deadlines. Please find our full response and recommendations in the document attached.

PWYP is committed to a fair use of extractive resources. We have been actively monitoring the development of the European sustainability reporting standards, recognizing the vital role of Environmental, Social, and Governance (ESG) reporting in achieving our goals.

B Lab recommends that EFRAG resumes its work on sector-specific standards and makes them available to companies. As a sustainability certification standard-setter, our track record of almost 20 years in engaging with companies which have no antecedents in corporate sustainability indicates that beginner-level companies perform better within a detailed framework.

Climate Focus opposes the European Commissions proposal to postpone sector-specific sustainability reporting standards under the Corporate Sustainability Reporting Directive (CSRD) by two years. We strongly urge the Commission, the European Parliament, and the Council of the European Union to promptly adopt and implement the sector-specific standards.

CDP evidence shows the importance of sector-specific information for investors. Since 2018 CDP has been requesting companies to fulfil sector-specific questions based on their primary activities. The move towards sector-specific questions was called for by investors to enable easier and more meaningful comparison on company progress.

European sustainability reporting standards (ESRS) postponement of deadlines under the Accounting Directive Fairtrade International welcomes the opportunity to give feedback on the proposal to delay the adoption of sector-specific standards related of the Corporate Sustainability Reporting Directive (CSRD) We work in agriculture and textiles with more than 2 million farmers and workers from 70 countries, with almost…

Walk Free is an international human rights group working to accelerate the end of all forms of modern slavery. We are the creator of the Global Slavery Index, the world's most comprehensive data set on modern slavery. We work with governments and regulators, businesses and investors, survivors, and faith and community leaders to drive systems change.

Assogestioni strongly believes in the need of a regulatory framework that can ensure that sustainability reporting standards for companies are complete, clear and useful in identifying and assessing the impact of their activities on workers, communities, consumers and the environment, impacts often related to the specificity of the sector to which the company belongs.

The Fair Trade Advocacy Office (FTAO) welcomes the European Commissions legislation on Corporate Sustainability Reporting. We believe that this is an important step towards accountability, transparency and responsible business conduct. Both the garment sector and agricultural sector have a high risk of human rights violations and negative environmental impacts.

FAIR/Campagna Abiti Puliti, the Italian section of the Clean Clothes Campaign, welcomes the approval of the CSRD and the ESRS but calls for a timely and strong approval of the sector-specific ESRS, particularly for sectors that are well known for being at high risk of negatively impacting human rights, the textile sectors being amongst these.

Dear Madam, Dear Sir, As association of German listed and capital markets-oriented companies, Deutsches Aktieninstitut represents almost 90 percent of the DAX-market capitalization. We welcome the opportunity to comment on the Proposal for a decision amending Directive 2013/34/EU as regards the time limits for the adoption of sustainability re-porting standards for certain sectors and for certain third-country…

The European Commission has proposed to delay from 2024 to 2026 the adoption of sector-specific standards (ESRS Set 2) in the Corporate Sustainability Reporting Directive (CSRD) for companies sustainability reporting. I. The Commissions delaying proposal is counterproductive : it will increase not decrease the corporate sustainability reporting burden 1.

Investors have been anticipating the forthcoming release of sector-specific European Sustainability Reporting Standards and are eager to avoid any further delay in their release. We urge the European Commission to consider our following recommendations: Finalization and adoption of the standards for the following high-impact sectors by 2025 [Oil and Gas; Mining, coal and quarrying; Road Transport; Textiles…

E3G welcomes the possibility to respond to the open consultation launched by the European Commission on the postponement of sector-specific ESRS. We acknowledge the European Commissions commitment to establish a balanced regulatory framework for corporate sustainability reporting, targeted at achieving transparent, high-quality sustainability information while avoiding unnecessary burdens for companies.

European Sustainability Reporting Standards: Postponement of deadlines under the Accounting Directive: ECIIA views We thank the opportunity to share our views on delaying the adoption of the specific standards (in the context of the EU Corporate Sustainability Reporting Directive), until 2026.

The Economy for the Common Good (ECG) welcomes the opportunity to comment on the European Commission´s (EC) proposal for a decision of the European Parliament and of the Council amending Directive 2013/34/EU (Accounting Directive) referred to above, regarding the adoption date of European Sustainability Reporting Standards (ESRS) for undertakings active in certain sectors and for certain third-country undertakings.

The reform of the European Union's legal framework for corporate extra-financial reporting (CSRD), supplemented by the adoption of sector-agnostic sustainability standards, applies to companies in all sectors and requires the adoption of additional sector-specific sustainability standards by 2024.

Finance Finland (FFI) sees that additional time to develop the robust and relevant sector-specific disclosure requirements and third company reporting requirements is needed at this stage. FFIs view is that the postponement of sector-specific standards from 30.6.2024 is justifiable as the first batch of draft standards havent yet been published for commenting.

The German Tax Consultants Association (DStV) welcomes the Commission’s proposal for a decision amending Directive 2013/34/EU as regards the deadlines for adopting sustainability reporting standards for certain sectors and certain third-country undertakings (2023/0368 (COD)), announced in the SME relief package.

Filed in German · English published by the European Commission

Disclosure remains the foundation of the EUs Sustainable Finance Action Plan, and the ESRS are an essential component of this. They establish the parameters for the detailed, credible and comparable reporting needed by investors to assess their exposures to climate-related risks and opportunities, inform stewardship activities and investment decisions, and reorient capital in line with a net zero world.

The development of high-quality sector-specific European Sustainability Reporting Standards is necessary to ensure that companies report on sector-specific topics and metrics of relevance to workers, communities, consumers and the environment.

ecoDa is concerned about the ability of European companies targeted by the CSRD to meet all the legal requirements that will be imposed on them in an excessively short period of time. However, groups well advanced in sustainability reporting have indeed expressed a view that the overall implementation of the CSRD will benefit from early access to sector-specific standards so that the full scope of required…

We write to underscore the critical importance of promptly adopting sector standards in the realm of sustainability reporting. The adoption of these standards is indispensable for companies to effectively implement ESRS Set 1 and navigate the intricate landscape of disclosure.

The Initiative for Responsible Mining Assurance is tracking development of sector-specific European Sustainability Reporting Standards (ESRS) for the mining sector under EFRAG and their proposed delay. We urge the European Commission to adopt a robust standard for the mining sector paired with independent third-party auditing and transparent reporting, without delay.

BEUC, the European Consumer Organisation, disagrees with the Commission's proposal to postpone by two years the sector-specific sustainability reporting standards that the Corporate Sustainability Reporting Directive (CSRD) requires.

The proposal to postpone the adoption deadline for sector-specific European Sustainability Reporting Standards (ESRS) and extend the timeline for non-EU companies risks losing the momentum that the recent adoption of the ESRS Set 1 generated. Companies need comprehensive guidance and incentives to feel empowered to commit to their respective decarbonization journeys.

The Association of German Public Insurers welcomes the initiative of the European Commission to lower the reporting obligations for companies by 25 per cent. With this in mind, the public insurers are in favour of the proposal to postpone the application of the sector-specific European Sustainability Reporting Standards (ESRS) in accordance with the Corporate Sustainability Reporting Directive (CSRD) by two years.

NRGI envisions a world where natural resources enable fair, prosperous and sustainable societies, instead of undermining them. Given that Environmental, Social and Governance reporting is essential to this goal we have closely followed the development of the European sustainability reporting standards.

Mr WELFARM took note of the proposal for a decision of the European Parliament and of the Council on the amendment of the deadline for adoption of the standards of Directive 2013/34/EU. On the other hand, WELFARM welcomed the inclusion of animal welfare as one of the issues that the companies covered by this text should address as part of their CSR policy and non-financial performance reporting.

Filed in French · English published by the European Commission

Business and Human Rights Resource Centre is concerned about the recent proposal to delay the adoption of sector-specific standards, particularly for the mining industries. As pressure intensifies to extract the minerals critical for the global energy transition, human rights abuses remain a damning feature of the sector.

T&E strongly believes that the development and adoption of sector-specific standards is crucial to help companies in their materiality assessment, reducing costs and making the reporting processes easier, while ensuring investors have access to meaningful information and auditors exercise is simplified.

Frank Bold welcomes the opportunity to provide feedback on the decision to postpone the draft Delegated Acts on the Sector Specific ESRS. Our response reflects the concerns discussed among members of the Alliance for Corporate Transparency, and its partners from business and investors communities.

The European Commission committed itself to reducing burdens associated with reporting requirements by 25%. In order to relieve undertakings subject to reporting requirements, the Commission plans to give them sufficient time to prepare for any new reporting requirements.

As DHL Group, we express our appreciation for the Commission's decision to postpone the implementation of sector-specific standards within the CSRD until June 2026. This extension grants EFRAG additional time to develop relevant disclosure requirements, a move we firmly support.

Climate & Company would like to express its encouragement and support of the timely adoption and usage of sector-specific standards (henceforth: sector standards) 1. Timely adoption of the sector standards is essential a.

Accountancy Europe strongly supports ECs efforts to transition EUs economy for a sustainable future. Sustainability reporting is one of the many necessary supporting tools to make this ambition a reality. Our suggestions below are intended to reinforce this objective.

There is an urgent need for high-quality sector-specific European Sustainability Reporting Standards. Human rights abuses and environmental impacts in high-risk sectors are of an intensity that does not warrant delays. Furthermore, the lack of guidance in sector-specific standards while still asking companies to report under CSRD and other legal frameworks, is actually counterproductive.

Eurogroup for Animals notes the Commissions proposal on the postponement of deadlines under the Accounting Directive for the adoption of European Sustainability Reporting Standards (ESRS). We hope the postponement provides sufficient time to develop high-quality ESRS, including on animal welfare.

ECOS recognizes the Commission's commitment to reducing regulatory burdens while fostering long-term competitiveness. Nevertheless, delaying the implementation of sector-specific standards will not alleviate the reporting burden, making this proposal counterproductive.

ANIA, the Italian Insurance Association, supports the European Commission proposal for a decision aiming at a 2-year postponement of the date of adoption of the sector-specific ESRS (and those to be used by certain non-EU companies).

Regarding the proposal, Reclaim Finance underlines that: 1) The development and adoption of sector-specific standards for high impact sectors must be prioritised in order to provide clarity for companies in these industries on what must be reported for their particular risks and impacts.

The development of high-quality sector-specific European Sustainability Reporting Standards is necessary to ensure that companies report on sector-specific topics and metrics of relevance to workers, communities, consumers and the environment.

Thank you for the possibility to comment on the planned extension to 30 June 2026 (instead of 30 June 2024) of the deadline for the adoption of sector-specific European sustainability reporting standards (ESRS) by means of delegated acts by the Commission in accordance with the third subparagraph of Article 29b(1).

Filed in German · English published by the European Commission

The development of high-quality sector-specific European Sustainability Reporting Standards is necessary to ensure that companies report on sector-specific topics and metrics of relevance to workers, communities, consumers and the environment.

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