Corporate Sustainability Reporting Directive

Deutsche Börse Group (DBG) would like to thank the European Commission for the opportunity to comment on the proposal for a Corporate Sustainability Reporting Directive (CSRD). We welcome the further development of the requirements for sustainability-related corporate reporting, both as a market infrastructure provider as well as a listed and thus reporting company.

We fundamentally endorse the European Commission's proposal for a new Corporate Sustainability Reporting Directive (CSRD). Our enclosed feedback document is based on the Value Balancing Alliance's (VBA) experience of developing a global and standardized impact measurement and valuation methodology and on the perspective of the real economy which the VBA members represent.

DI generally supports a more consistent and comparable sustainability reporting on a global level. We therefore believe that the review of the former Non-Financial Reporting Directive as proposed with the CSRD is very timely. It should be recognised that with the NFRD, the EU went to the forefront of sustainability reporting.

EC consultation on the proposal for a Corporate Sustainability Reporting Directive (CSRD) A Eurelectric response paper July 2021 Eurelectric represents the interests of the electricity industry in Europe. Our work covers all major issues affecting our sector. Our members represent the electricity industry in over 30 European countries.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We connect Polish Business and Science with the EU Ref. Ares(2021)4571910 - 14/07/2021 #BSP_Paper Lipiec 2021 Sprawozdawczość przedsiębiorstw w zakresie zrównoważonego rozwoju - CSRD 1. Wstęp Business and Science Poland z zadowoleniem przyjmuje możliwość skomentowania wniosku dotyczącego dyrektywy o sprawozdawczości przedsiębiorstw w zakresie zrównoważonego rozwoju (CSRD/NFRD).

Filed in Polish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EnBW welcomes the proposals for the revision of the CSR Directive published by the EU Commission on 21 April 2021. We support the goal of increasing transparency with regard to sustainable aspects and thus meeting the growing demand for sustainability-related information to an even greater extent.

The attached document contains feedback of the SMEunited secretariat on the proposal on corporate sustainability reporting adopted by the European Commission. The main comments were already made during several conferences in the last months and on our website. A final position paper of SMEunited will follow after the summer break.

Ref: Corporate Sustainability Reporting Link to consultation: https://ec.europa.eu/info/law/better-regulation/have-yoursay/initiatives/12129-Corporate-Sustainability-Reporting_en BETTER FINANCE feedback on Corporate Sustainability reporting About BETTER FINANCE BETTER FINANCE, the European Federation of Investors and Financial Services Users, is the public interest non-governmental organisation advocating and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Center for Sustainable Governance (CSG) of the Bielefeld Higher School of Small and Medium-sized Enterprises, which has set itself the objective of specifying (extensive, but abstract) environmental, social and economic criteria in sectors and businesses, monitoring their compliance and thus being able to monitor development, makes the following comments on the European Commission’s proposal for a directive of…

Filed in German · English published by the European Commission

This is only a cut in our feedback. The full feedback can be found in the attached PDF. We express our opinion on the proposal for a Directive of the European Parliament and of the Council amending Directives 2013/34/EU, 2004/109/EC and 2006/43/EC and Regulation (EU) No 537/2014 as regards corporate sustainability reporting (COM (2021) 189 final 2021/0104 (COD)), published on 21.4.2021. ... I.

Filed in German · English published by the European Commission

Caisse des Depots Group much supports the proposal of directive of the Commission related to corporate sustainable reporting and considers it a crucial tool to ensure financing is directed towards the European green transition, as well as to provide the necessary data for a better integration of ESG criteria into investment decision making processes.

POSITION | SUSTAINABILITY REPORTING | CSRD The new Corporate Sustainability Reporting Directive 14 July 2021 Businesses call for a global standard German industry attaches great importance to sustainability reporting. German companies have supported and continuously developed numerous international frameworks.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We welcome the Commission’s proposal and we believe that this initiative will help us to demonstrate our commitment to the European Union’s ambitious plan to transform Europe into the first climate-neutral continent and to become the first zero-emissions logistics provider by 2050.

ENI’s Position – Corporate Sustainability Reporting Directive Eni welcomes the proposal of the European Corporate Sustainability Reporting Directive that aims at improving the quality and the comparability of the information provided, according to a double materiality approach.

Filed in Italian · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Foreign Trade Association of German Retailers (AVE) welcomes the work of the European Commission on Sustainable Finance and Sustainability Disclosure as part of its holistic approach to drive social and environmental sustainability under the framework of the European Green Deal.

ClientEarth welcomes the review of the Non-Financial Reporting Directive (NFRD) which intends to provide more robust provisions to tackle the poor quality of sustainability disclosures. Reporting requirements under the NFRD have resulted up to now in the disclosure of limited information for investors and other stakeholders including civil society organisations.

IOSH welcomes the opportunity to comment on the ‘Impact Assessment’ as part of the ongoing process for a CSRD. Based on the recommendations to move forward incorporated in the Impact Assessment document for the Revision of the Non-Financial Reporting Directive we would like to reconfirm IOSH’s position, rationale and arguments: • Our recommended preference is for a mandatory, horizontal, cross-thematic due diligence…

The EACB considers the CSRD extremely important for the full achievement of the sustainable finance framework and welcomes many of the proposals. Our answer to the consultation represents our co-op banks members’ views as both users and preparers of sustainability reports. Please see below our comments.

The Association for Financial Markets in Europe (AFME) and the International Swaps and Derivatives Association (ISDA) believe that the European Commission’s proposal for a Corporate Sustainability Reporting Directive represents an important step towards improving the quality and availability of sustainability information.

Global Witness welcomes the proposed Corporate Sustainable Reporting Directive as this is critical to meet the EU's transition towards a sustainable and resilient economy. However, in order to have a meaningful impact, there must be urgent amendments made to the proposal in the co-legislative process to strengthen the proposal: 1.

Oesterreichs Energie welcomes the European Commission’s proposal on corporate sustainability reporting as an important contribution towards a sustainable financing strategy for the Green Deal. Extension of the scope of the Corporate Sustainability Reporting Directive (CSRD) to all large companies (with over 250 employees) will certainly result in a series of new and additional reporting obligations, which in turn…

To: European Commission, Head of Unit for Corporate Reporting ILA on the European Commission’s draft Corporate Sustainability Reporting Directive (CSRD) Please find ILA's feedback attached. Yours faithfully, [name removed] Legal executive Institut Luxembourgeois des Administrateurs (ILA) Association sans but lucratif

CDP Europe welcomes the European Commission’s (EC) renewed NFRD and proposal for Corporate Sustainable Reporting Directive (CSRD). It is encouraging that the CSRD is TCFD aligned and seen as a platform upon which to build wide-reaching reporting standards compatible with potentially forthcoming international standards.

BVI position on the European Commission's proposal for the "Corporate Sustainability Reporting Directive" (CSRD) The revision of the EU framework for non-financial reporting is key to achieving the objectives of the EU Action Plan on Financing Sustainable Growth.

As a business organisation with sustainability at the core of its mission, amfori welcomes the recent publication by the EU Commission of its proposal for a Corporate Sustainability Reporting Directive (CSRD). The attached paper outlines amfori’s views on the CSRD proposal as recently presented by the European Commission in April 2021.

Repsol feedback to the Corporate Sustainability Reporting Directive proposal We support the goal of ensuring a consistent approach to reporting across different pieces of legislation. This will improve comparability of sustainability information across sectors and companies and result in a better-informed decision making for stakeholders.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The IDW supports the Proposal for a CSRD. Our attached letter discusses the following: A globally accepted basis for sustainability reporting will be essential to sustainable growth in Europe. EFRAG should examine which aspects of sustainability reporting shall be addressed at the global level. Implementation deadlines will pose significant challenges to all parties affected.

We welcome the further development of the EU Sustainable Finance Agenda and the opportunity to provide feedback on the draft legislative act as proposed by the European Commission. Reliable, comparable and relevant information on companies’ exposure to sustainability risks will enable informed decision-making that fosters investment in economic activities contributing to the socially just and sustainable economic…

ETUC Reply to the European Commission’s Public Consultation on Corporate Sustainability Reporting The draft Corporate Sustainability Reporting Directive (CSRD) would help to implement a single set of mandatory reporting standards for European companies.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Invest Europe welcomes the CSRD proposal. As a data driven industry, we support the view that to achieve sustainable and inclusive growth it is key to have relevant, comparable and reliable sustainability information as a pre-requisite for tracking progress and, ultimately, meeting the EU sustainability targets.

World Animal Protection welcomes the EU initiative aiming at further embedding sustainability into corporate governance, which would amend the reporting requirements of the Non-Financial Reporting Directive (NFRD). In that context, we strongly believes that the concept of non-financial reporting currently developed at the EU level should encompass animal welfare.

Bloomberg welcomes the European Commission’s (EC) proposal for a Corporate Sustainability Reporting Directive (CSRD). This marks an important milestone in the EU’s path to a sustainable economy, and Bloomberg remains committed to continuing to support the sustainable finance agenda as part of the EC’s global leadership on climate change.

With the publication of the proposed Corporate Sustainability Reporting Directive (CSRD), Cefic welcomes further development of the EU Sustainable Finance Agenda. Reliable, comparable and relevant information on companies’ exposure to sustainability risks will enable informed decision-making that fosters investment in economic activities contributing to the socially just and sustainable economic transition.

The PGE Group would like to highlight the following issues with regard to the proposed revision of the Non-Financial Reporting Directive (NFRD). 1. We welcome the extension of the scope of the Corporate Sustainability Reporting Directive (CSRD) to all large companies, which in our opinion will allow for the creation of level-playing field. 2.

July 2021 Corporate Sustainability Reporting Directive: Preliminary views for the European Banking Sector Submission to the European Commission’s request for feedback The EBF welcomes the European Commission's proposal for the Corporate Sustainability Reporting Directive.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Eurogroup For Animals welcomes the EU initiative aiming at further embedding sustainability into corporate governance, which would amend the reporting requirements of the Non-Financial Reporting Directive (NFRD). In that context, Eurogroup For Animals strongly believes that the concept of non-financial reporting currently developed at the EU level should encompass animal welfare.

The targets of the proposed legislative act are acceptable. In particular, we agree on the broadening of the scope of application of corporate sustainability disclosure to include all big companies and listed companies (except for SMEs), the assurance requirement of sustainability disclosure, the more detailed definition of the information that companies should disclose.

AmCham EU supports the objectives of the European Commission’s proposal for a Corporate Sustainability Reporting Directive (CSRD). The proposal would improve environmental, social and governance (ESG) disclosures and lead to greater relevance, comparability and reliability of ESG reporting across the EU.

UNICEF thanks the European Commission for the opportunity to provide feedback on the proposed Corporate Sustainability Reporting Directive (CSRD). We welcome the leadership of the European Union (EU) in promoting processes and mechanisms to support responsible and sustainable business conduct based on the principle of double materiality and in alignment with international human rights standards, the UN Guiding…

Position Paper 14 July 2021 CORPORATE SUSTAINABILITY REPORTING DIRECTIVE Executive summary • The business community is fully committed to global sustainability and to driving investment more into sustainable activities. More and more companies take an active role in this by integrating sustainability in business strategies and practices.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

AllianzGI response to the European Commission’s consultation on the proposed Corporate Sustainability Reporting Directive Key Messages: • • • • • • Important step. Allianz Global Investors (“AllianzGI”) is supportive of the Corporate Sustainability Reporting Directive (“CSRD”) proposal as an important step in the right direction.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The CEZ Group would like to highlight, that the obligation of integrating the sustainability reporting in the management report would put an extreme time pressure on undertakings and would be very demanding from the administration and associated costs point of view.

UNI (Ente Italiano di Normazione) and ACCREDIA (Italian Accreditation Body) enclose a proposal for an amendment to the text of the Proposal for a Directive of the European Parliament and of the Council amending Directive 2013/34/EU, Directive 2004/109/EC, Directive 2006/43/EC and Regulation (EU) No 537/2014 as regards corporate reporting on sustainability.

Filed in Italian · English published by the European Commission

The Economy for the Common Good (ECG) movement strongly supports the European Commission's initiative to improve sustainability impact reporting in the European Union. ECG is a social movement advocating for a future-fit economic model which is beneficial to all stakeholders of an organisation: employees, suppliers, customers, business partners, the local community and society at large, as well as the planet and…

CONSULTATION RESPONSE Ref. Ares(2021)4557668 - 14/07/2021 JULY 2021 IOGP position on the “European Commission proposal on the update of the Corporate Sustainability Reporting Directive” Introduction IOGP, the International Association of Oil and Gas Producers whose member companies account for approximately 90% of oil and gas produced in Europe, supports the goals of the Paris Agreement and the EU’s ambition to…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Japan Business Council in Europe (JBCE) supports the European Commission’s proposal to enhance companies’ disclosure of corporate sustainability information, encompassing not only the environmental aspect, but also social and governance aspects. JBCE recognises the contribution that this legislation will make in the sustainable growth of companies.

European Commission Attn Mr John Berrigan DG FISMA 1049 Brussels 13 July 2021 Subject: European Contact Group (ECG) feedback on the proposal for a Corporate Sustainability Reporting Directive Dear Mr Berrigan The European Contact Group (ECG)1, which brings together the six large professional services networks in Europe (BDO, Deloitte, EY, Grant Thornton, KPMG and PwC), welcomes and generally supports the proposed…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Salesforce is pleased to provide comments to the European Commission’s public consultation on the adopted proposal for a Directive of the European Parliament and of the Council amending Directive 2013/34/EU, Directive 2004/109/EC, Directive 2006/43/EC and Regulation (EU) No 537/2014, as regards corporate sustainability reporting (henceforth referred to as the “CSRD”).

EuropeanIssuers welcomes the opportunity to present its feedback on the Commission’s proposal for a Corporate Sustainability Reporting Directive, for which you may find a full complete response in attachment. In sum, EuropeanIssuers shares the ideal aim of the proposed Directive to enhance transparency and promote sustainable investments.

EY Europe SCRL/CVBA De [address removed] Mr. [name removed] DG FISMA European Commission Rue de Spa 2 BE – 1000 Brussels 14 July 2021 Subject : Corporate Sustainability Reporting Directive – EY’s response to the consultation Dear Mr.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

PensionsEurope welcomes the opportunity to comment on the proposal of the EU Corporate Sustainable Reporting Directive (CSRD). IORPs as investors are users of the data which companies will be required under the legislative proposal for a Corporate Sustainability Reporting Directive.

T&E welcomes the revised and renamed Corporate Sustainability Reporting Directive, which is an important milestone within the wider EU Sustainable Finance framework, the overarching goal of which is to channel the financial flows towards truly impactful and sustainable activities. We applaud in particular, the following elements: 1. Scope – extended and clarified, to include for all large and listed companies 2.

POSITION PAPER Comments on the proposal for a directive as regards corporate sustainability reporting Answer to the public Consultation – 14/07/2021 The Commission presented its proposal for a Corporate Sustainable Reporting Directive on 21 April.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ICOS is the umbrella body for over 130 co-operatives in Ireland – including Irish dairy processing and milk purchasing co-operatives, livestock marts and other rural based enterprises – whose associated businesses have a combined turnover in the region of €14 billion, with some 150,000 individual members, employing 12,000 people in Ireland, and a further 24,000 people overseas.

Copa-Cogeca is the united voice of farmers and their agri-cooperatives. It represents 22 million farmers and their family members as well as 22,000 cooperatives operating in the agri-food, forestry, and fishery sector. The companies that Copa-Cogeca represent are mainly micro, small and medium enterprises.

The Bavarian Chamber of Commerce and Industry (BIHK) [Bavarian Chamber of Commerce and Industry] is grateful for the opportunity to submit its comments. As the umbrella organisation of the nine Bavarian CCIs, the BIHK speaks for more than 990.000 member companies of all sizes and sectors.

Filed in German · English published by the European Commission

Europe's new Corporate Sustainability Reporting Directive – Involving companies to ensure a successful transition to a sustainable economy! Feedback on the Proposal for a Corporate Sustainability Reporting Directive, 14 July 2021 EUROPE’S NEW CORPORATE SUSTAINABILITY REPORTING DIRECTIVE Introduction Climate change and the necessary transition to a resource -conserving and climate-neutral economy require a…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Association for Sustainability and Environmental Management (VNU) supports the commitment to sustainability in conjunction with valid reporting for organisations. We recommend that greater use be made of EMAS, as EMAS has been established for many years and in particular combines all demands for CSR and sustainability as part of a management system.

Filed in German · English published by the European Commission

Dear Sir/Madam, On behalf of the Deloitte firms in the European Union (EU) and Deloitte Global, we are pleased to provide feedback on the proposal for a Corporate Sustainability Reporting Directive (CSRD). We welcome the leadership the EU has shown in this arena and share the need to accelerate sustainability reporting (SR) to serve the EU policies to succeed in a green and inclusive economic transition and meet the…

ALFI warmly welcomes the CSRD proposal that will ensure that much more ESG reliable data are available in the European market. This is key to enable FMPs to satisfy their reporting duties under SFDR. We are nevertheless concerned about the application timeline: per the current timetable, CSRD reports will be available at best in 2024 (in respect of the 2023 financial year), whereas SFDR reporting requirements will…

Dear, Please find attached our contribution on the proposal for a Directive of 21 April 2021 amending Directives 2013/34/EU, 2004/109/EC, 2006/43/EC and Regulation (EU) No 537/2014 as regards disclosure of sustainability information by companies.

Filed in French · English published by the European Commission

DUFAS strongly supports the development of a solid corporate sustainability reporting framework and sustainability standards. We believe that CSRD will improve the quality of sustainability information and increase the comparability of ESG data between investee companies.

ECIIA reaction ECIIA welcome the European Commission’s initiatives in the sustainability areas (CSRD and Standards by EFRAG) and the positioning of Europe, well advanced in these matters. The ECIIA is the voice of internal audit in Europe. Our role is to enhance corporate governance through the promotion of the professional practice of internal auditing.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Mouvement des entreprises de France (Medef) is the main French business association, representing companies of all sizes and sectors, both issuers and investors. Medef welcomes the opportunity to comment on the proposal for a directive on corporate sustainability reporting.

AFEP (the French Association of Large Companies) considers that the revision of the current Non-Financial Reporting Directive (NFRD) is necessary in order to harmonise and standardise sustainability reporting and to end the proliferation of frameworks and standards.

We welcome the change of name from Non-Financial to Corporate Sustainability Reporting, as it recognizes the intrinsic linkages between what was seen as “financial” and “non-financial” considerations. It also highlights the importance of embedding sustainability in all critical areas of a company’s activities that can be clearly articulated through a comprehensive reporting process with double materiality at the…

The German Association of Energy and Water Industries (BDEW) represents over 1,900 companies along the entire value chain of electricity and heat production and transmission as well as drinking water extraction and wastewater disposal. As such, we and our members are committed to the European Green Deal, the corresponding climate targets and the necessary transformation of the energy system.

As an integrated partnership delivering audit services to PIEs across 24 EU Member States, Mazars welcomes the Commission initiative to define and coordinate sustainability reporting and assurance requirements at EU level, in order to make companies more accountable for their social and environmental impact, provide investors and other stakeholders with reliable, relevant and comparable information and, in line with…

The French Insurance Federation (FFA) welcomes the proposal on a Corporate Sustainability Reporting Directive (CSRD). The newly suggested framework is highly relevant. French insurers particularly approve: - The concept of double materiality and the fact the CSRD encompasses the broad spectrum of sustainability topics (ESG pillars). - The extension of the scope to cover a wider part of the investment universe.

The UGA Board welcomes in principle the qualitative and quantitative improvement of the CSRD. In particular, it supports a meaningful review of the content of the reported information on sustainability issues. The draft Directive provides for the possibility of verifying this information also by auditors covered by the Accreditation Regulation (EC) No 765/2008. This option is strongly welcomed.

Filed in German · English published by the European Commission

Independent Retail Europe is the voice of groups of independent retailers in the food as well as non-food sectors at EU level. We generally support the EU’s ambition for companies to include sustainability into their strategies.

SBR Nexus strongly supports future reports on sustainability. In the Netherlands, the public authorities and, inter alia, the banks are connected through the ESBR Arrangements system in which the digital exchange is agreed jointly. This digital exchange uses the SBR and XBRL standards. these agreed standards provide for cheaper and better quality data exchanges.

Filed in Dutch · English published by the European Commission

The EAPB supports the planned transformation to a sustainable economy in Europe. The legislative proposal for a “Corporate Sustainability Reporting Directive” is an important step towards harmonised sustainability reporting. New reporting requirements seem to be rather ambitious, in terms of both content and timing. This applies especially to those companies and banks, which should report for the first time.

HSE Group thanks the Commission for its opportunity to provide feedback on the revision of the Non-financial Reporting Directive. We welcome the overall sustainable finance initiative of the European Union and the Commission's plans to establish unified and transparent sustainability reporting to respond to the growing demand for information from investors and civil society.

The public insurers are signatories of the Principles for Responsible Investment (PRI) and take environmental, social and governance principles into account in their investment decisions. In this light, the public insurers strongly support improved sustainability data. The Sustainable Finance Disclosure Regulation (SFDR) requires insurers to report an extensive set of sustainability data of their investments.

The VDMA welcomes this opportunity to comment on the EU Commission's proposal to revise the Non-Financial Reporting Directive (NFRD) - in the future called CSR Directive (CSRD). CSR reporting is becoming increasingly important for companies in the mechanical and plant engineering sector, as they are continuously developing sustainable products and production technologies.

econsense – Forum for Sustainable Development of German business is a network of 40 large international companies dedicated to sustainability. Sustainability reporting has a long tradition among our members and we welcome the EU Commission’s ambition for an upgrade of sustainability reporting.

Nordic Securities Association (NSA) welcomes the Commission’s proposal to harmonise and standardise companies’ sustainability reporting. We are overall supportive of the ambitious proposal. It is now important to stay ambitious in the forthcoming political and standard development process. In particular, this applies to the following areas: • consistency to requirements to the financial sector, cf.

Banco Bilbao Vizcaya Argentaria (BBVA) welcomes the proposal adopted by the European Commission on April 21st, for a Corporate Sustainability Reporting Directive (CSRD), which would amend the existing reporting requirements of the NFRD. To date, the information provided under the current framework is scarce, incomplete and hardly comparable.

We appreciate the opportunity to comment on the EU COM’s consultation on its proposal for the Corporate Sustainability Reporting Directive (CSRD). The attached paper summarizes Allianz Group’s position, which we hope will be considered in the finalization of the CSRD.

ACCA supports the EU’s leadership in promoting the adoption of sustainable business models throughout the EU. Reporting is one part of the solution alongside sustainable finance, corporate governance, taxation and regulation. We need to minimise undue compliance burden on companies, conserving business resources so they can be spent on green and just transition.

ICAEW welcomes the opportunity to provide feedback on the CSRD proposals, published on 21 April 2021. Building more sustainable and resilient net-zero economies calls for a fresh look at corporate reporting: the proposals address important issues around sustainability reporting, standards and assurance.

France Invest’s members have been committed to Environmental, Social and Governance (ESG) matters for long. In this context, we welcome the Commission’s proposal for a Directive on corporate sustainability reporting (CSRD).

Assonime welcomes the opportunity to present its feedbacks on the European Commission Proposal on new Sustainability Reporting requirements. We share Commission’s primary goal of having a clearer and more coherent reporting framework within the EU.

WBCSD is a global, CEO-led organization of more than 200 leading businesses, working together to accelerate the transition to a sustainable world. We help make our member companies more successful and sustainable by focusing on the maximum positive impact for shareholders, the environment and societies.

Dear Sir/Madam, Thank you for the opportunity to comment on the European Commission’s proposal for a Directive on Corporate Sustainability Reporting Directive. The Federal Association of the German Confectionery Industry (BDSI) represents the economic interests of more than 200 mostly medium-sized German confectionery companies. He is an association of both business and employers.

Filed in German · English published by the European Commission

AIAF, Standard setter for Financial Analysis, with round 1000 members in Italy and, under the coordination of EFFAS “The European Federation of Financial Analysts Societies”, operating in 23 European countries with round 16000 members welcomes the opportunity to provide some feedback on the recent EU proposal to review the Non-Financial Reporting Directive (NFRD), renamed as the “Corporate Sustainability Reporting…

BASF shares the Commission’s view on the Non-Financial Reporting Directive (NFRD), that its goal of improving comparability and readability for users, notably the investors, has only partially been reached. BASF and companies all over the world face increasing reporting demands from stakeholders, with sometimes conflicting objectives.

FEBIS members welcome the European Commission’ draft of Corporate Sustainability Reporting Directive (CSRD) unveiled at the end of April 2021 and which aims at facilitating non-financial reporting and considering all aspects relating to economic, social and governance items in company reporting.

FEEDBACK STATEMENT The Dutch Accounting Standards Board (DASB) / Raad voor de Jaarverslaggeving (RJ) welcomes the opportunity to provide some general feedback on the proposal for the EU Corporate Sustainability Reporting Directive (CSRD). Positive development The DASB is in general very positive about this important CSRD-proposal requiring corporate sustainability reporting.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The GDV highly welcomes the EU Commission’s legislative proposal for the CSRD as an important foundation for sustainable finance. Indeed, the new CSRD – if aligned – can be a real game-changer for the sustainability agenda if it enhances market transparency, availability and quality of sustainability information.

The Confederation of Small and Medium-sized Enterprises (CPME) is an inter-branch employers’ organisation representing 200 federations and trade unions in the trade, services, industry and crafts sectors. It also includes federations representing the liberal professions and the social and solidarity-based economy.

Filed in French · English published by the European Commission

Dear Members of the EU-Commission, the German association of industrial energy consumers (VIK e.V.) welcomes an opportunity to provide feedback on the Proposal for a Directive of corporate sustainability reporting. Please find attached our position paper. Kind regards, German association of industrial energy consumers.

Insurance Europe is very supportive of the CSRD initiative. As Europe’s largest institutional investor with €10 trillion of investments, it is vital that consistent, comparable and machine- readable sustainability data is available so insurers can make appropriate investment decisions and comply to the European regulatory disclosure requirements (SFRD and Taxonomy).

Polish Chamber of Insurance welcomes the European Commission proposal for a better standardization and harmonization of sustainability reporting. It is vital that sustainability data is available so financial market participants can make appropriate investment decisions and comply to the Sustainable Finance Disclosure Regulation.

TCO is positive about a new directive that has the ambition to strengthen existing rules introduced by the NFRD. The information in sustainability reporting is an important source of information for trade union work. However, the data must be comparable comprehensive, relevant, and reliable in order to make it possible to evaluate companies' impact on the environment, society and people..

Shifting capitals towards more sustainable activities needs to be underpinned by a shared understanding of sustainability, based on accountable and transparent criteria to be measured and monitored through traceable metrics. To this extent, CDP welcomes the European Commission proposal for a better standardization and harmonization of sustainability reporting.

VNO-NCW welcomes the opportunity to provide feedback on the European Commission’s proposal for a Corporate Sustainability Reporting Directive (CSRD). In our view, economic recovery and a structurally higher economic growth are urgently needed, however it must be beneficial for society as a whole, in a sustainable living environment. Consequently, we are committed to transparency on sustainability.

Wiener Stadtwerke welcomes the European Commission’s proposal on sustainability reporting under the CSRD as an important contribution to a sustainable financing strategy for the Green Deal. However, extending the scope of the CSRD to include now all large companies (> 250 employees) will lead to a number of new and more reporting requirements in the relevant companies and thus to increased (financial and human)…

Filed in German · English published by the European Commission

NBA FEEDBACK STATEMENT NBA supports the ambitious EU-proposals for Sustainable Finance. After all, the urgency is high. The proposals offer an acceleration of the international harmonization of regulations and standards, which is highly needed. This is in line with the NBA's mission to enable accountants to make a relevant contribution to making organizations more sustainable, in the public interest.

For the FNTP, the main objective of the revision was to improve the comparability and readability of non-financial information by better aligning non-financial reporting requirements across EU countries and between companies in the same sector.

Filed in French · English published by the European Commission

EFET acknowledges the necessity for strengthening the Non-financial Reporting Directive reporting requirements on sustainability and increasing corporate reporting transparency in order to underpin the transition towards a sustainable paradigm.

JULY 2021 FEEDBACK TO THE CORPORATE SUSTAINABILITY REPORTING ADOPTED ACT INTRODUCTION The Danish Institute for Human Rights (DIHR) welcomes the recognition by the European Commission of the vital role that non-financial reporting plays in encouraging responsible business conduct and efforts to reform the Non-Financial Reporting Directive (NFRD) to address the existing gap between the sustainability information…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Stand: 08.07.2021 Stellungnahme Richtlinienvorschlag der Europäischen Kommission „Corporate Sustainability Reporting Directive, (CSRD-E)“ Hintergrund Mit dem Green Deal wird u.a. eine Transformation der Wirtschaft in Richtung Nachhaltigkeit angestrebt.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The French Banking Federation (FBF) welcome the European Commission’s proposal for a Corporate Sustainability Reporting Directive (CSRD). We would like to support the objective to improve efficiency and reliability of sustainability gaps.

Filed in French · English published by the European Commission

Reply from the members of the CSR Platform’s “Europe” working group on the proposal for a Directive on Corporate Sustainability Reporting Directive The CSR Platform welcomes this proposal for a Directive. More specifically, the CSR Platform welcomes the following provisions: (1) Recognition of the mandatory and standardised nature of non-financial or ESG reporting While many initiatives carried out by various…

Filed in French · English published by the European Commission

In order to develop regulations which will contribute to fulfill the growing demand for sustainability information without unnecessary burdens for companies, we suggest to consider the following issues: • The sustainability-reporting standards should be included in the CSRD Directive.

Comments from the Czech Insurance Association on the legislative proposal for Corporate Sustainability Reporting Directive 1. General In general, this legislative proposal, the CSRD, is an opportunity for ČAP members to comply with the new obligations of sustainable finance, while allowing access to this information to better manage ESG risks.

Filed in Czech · English published by the European Commission

Dear Commissioner, As President of the CNCC, the French institute of statutory auditors, I wish to express the overall support of the French profession to the Commission’s proposal for a Corporate Sustainability Reporting Directive (CSRD), including the development of European sustainability reporting (SR) standards by EFRAG. 1. This is because of: a.

The VKU welcomes the European Commission’s work on sustainable finance. However, in order to ensure the effectiveness of reporting obligations to achieve the sustainability and climate objectives, the VKU considers that adjustments to the Commission’s draft are still needed. In the following, the VKU assesses the key provisions of the proposal for a directive from the point of view of local government.

Filed in German · English published by the European Commission

Finance Finland (FFI) welcomes the Commission’s proposal to harmonise and standardise companies’ sustainability reporting. We are in favour of extending the reporting scope to large and listed companies, and to also include SMEs in the scope, although with more proportionate reporting obligations.

With the operationalisation of the taxonomy and the expansion of the NFRD/CSRD, the demand for business data is once again significantly increasing in terms of the ‘green’ value added. For example, the taxonomy will impose a specific obligation on large companies to disclose sustainability information under the CSRD.

Filed in German · English published by the European Commission

The climate emergency is clear to all. Transitioning requires fundamental change in policies and business practices. We commend the EC for its ambition to foster this change and for proposing the CSRD. All involved parties will have to play a balancing act between advancing quickly to meet the ambitious timeline and taking up the challenge of reporting credible and quality sustainability information as from 2024.

Pellervo Coop Center – representing some 4000 cooperative businesses in Finland - welcomes and supports the proposed Corporate Sustainability Reporting Directive (CSRD). We would like to provide feedback to ensure that the cooperative business model is also taken into account.

ecoDa, the European Confederation of Directors Associations, would like to share with you its various remarks relating to the public consultation on the Corporate Sustainability Reporting Directive. In general, ecoDa backs the approach of the European Commission which aims to encourage companies to more take into account the impact of their company on the surrounding ecosystem and to adopt a sustainable strategy.

Nachhaltigkeitsbezogene Unternehmensberichterstattung Richtlinienvorschlag der Europäischen Kommission DER MITTELSTANDSVERBUND bedankt sich für die Möglichkeit der Kommentierung des jüngst veröffentlichten Richtlinienvorschlags zur Änderung der Richtlinien 2013/34/EU, 2004/109/EG und 2006/43/EG und der Verordnung (EU) Nr. 537/2014 hinsichtlich der Nachhaltigkeitsberichterstattung von Unternehmen.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

On mission since 2020, MAIF warmly welcomes the draft CSRD, which sets ambitious disclosure requirements on corporate sustainability with a simple principle: More sustainable information from more companies. The CSRD is an ambitious text which should make it possible to release non-financial data from enterprises. 1.

Filed in French · English published by the European Commission

The Commission wants to elevate the status of sustainability reporting which is understandable because together with financial information it gives a comprehensive picture of a company. The proposal for a sustainability reporting directive includes various new aspects and would broaden the scope of sustainability reporting. However, it is good that non-listed SMEs would be left outside of the scope.

The Chamber of Tax Advisers and Accountants (KSW) is the umbrella organisation for all tax advisors and accountants in Austria. It represents more than 11.000 members. These are the specialists in tax consultancy and auditing and provide more than 95 % of Austrian businesses.

Filed in German · English published by the European Commission

Proposal for a Corporate Sustainability Reporting Directive amending Directive 2013/34/EU, Directive 2004/109/EC, Directive 2006/43/EC and Regulation (EU) No 537/2014, as regards corporate sustainability reporting 24.06.2021 The Austrian Federal Economic Chamber (WKÖ) is the legal representative of the entire Austrian business community and represents all Austrian companies – some 540,000 businesses drawn from the…

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FERMA is pleased to have the opportunity to provide the European Commission with feedback from the risk and insurance management community on its proposal for a Corporate Sustainability Reporting Directive [CSRD] (‘the proposal’). As the EU-level representative of the risk management profession FERMA has an important voice on the topic of sustainability.

Bundesministerium für Justiz BMJ - I 7 (Persönlichkeitsrechte, Gerichtsgebühren, zivilrechtliche Nebengesetze und Rechnungslegung [address removed] E-Mail: [email removed] Ihr Zeichen Unser Zeichen Bearbeiter/in Tel 501 65 GZ: 2021- BW-GSt/Mu [name removed], DW 12701 DW 142701 8.6.2021 [name removed] DW 12293 DW 142293 0.291.563 Fax 501 65 Datum Proposal for a Directive of the European Parliament and of the council…

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We are overall supportive of the ambitious proposal. It is now important to stay ambitious in the forthcoming political and standard development process. In particular this applies to the following areas: • consistency to requirements to the financial sector • expansion of scope to all large undertakings and all listed undertakings • mandatory standards for large undertakings • proportionate simplified standards for…

FAR, the Institute for the Accountancy Profession in Sweden, find it positive that sustainability reporting should be performed according to a standardized framework. In developing such a framework, it is important that the need for information in different stakeholders groups' are met both in terms of the general cross-industry- and the company-specific information.

The German Banking Industry Committee supports the planned transformation to a sustainable economy in Europe. The submitted legislative proposal for a “Corporate Sustainability Reporting Directive” is an important step towards harmonised sustainability reporting throughout Europe. Nevertheless, the implementation of the new reporting requirements seems to be rather ambitious, both in terms of content and time.

WIRTSCHAFTSPRÜFERKAMMER. Postfach 30 18 82. 10746 Berlin Wirtschaftsprüferhaus [address removed] European Commission 1049 Bruxelles/Brussel Belgium Phone [phone removed] Fax [phone removed] Email [email removed] Internet www.wpk.de June 21, 2021 WP 275/Weber Comment Letter on the Proposal for a Corporate Sustainability Reporting Directive (CSRD) Dear Ladies and Gentlemen We thank you for the opportunity to comment…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

IMA-Europe welcomes the opportunity to provide feedback on the recent proposal to revise the Non-Financial Reporting Directive (NFRD), renamed as the ‘Corporate Sustainability Reporting Directive (CSRD)’. Although IMA supports the efforts to create transparency and improve reporting, we wish to call attention in particular to the some outstanding issues which should to be addressed beforehand.

Ladies and gentlemen, we would like to thank you for the opportunity to comment on the European Commission’s proposal for a Directive on Corporate Sustainability Reporting Directive. Please find attached our opinion. [complimentary close] GdW Federal Association of German Housing and Real Estate Companies (Bundesverband deutscher Wohnungsungs- und Immobilienunternehmen e.V.)

Filed in German · English published by the European Commission

The Helicon, One South Place, London EC2M 2RB, United Kingdom Ref. Ares(2021)4038525 - 21/06/2021 T: [phone removed] aicpaglobal.com | cimaglobal.com | aicpa.org | cgma.org Association of International Certified Professional Accountants (Association) Response to the Consultation on EU Corporate Sustainability Directive (amending Directive 2013/34/EU, Directive 2004/109/EC, Directive 2006/43/EC and Regulation (EU) No…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ANIA, the Italian Insurance Association, fully supports the CSRD proposal and its aim to significantly improve sustainability information and corporate sustainability reporting and welcomes the opportunity to provide some feedback. ANIA recognises that the CSRD proposal goes in the right direction of making corporate sustainability reporting more consistent, comparable and reliable.

General comments The proposed Corporate Sustainability Reporting Directive (CSRD) is a central component of the sustainability reporting requirements underpinning the EU’s sustainable finance strategy, together with the Sustainable Finance Disclosure Regulation (SFDR) and the Taxonomy Regulation.

Iberdrola welcomes the revision of the Non-financial Reporting Directive leading to the Corporate Sustainability Reporting Directive. Reinforcing reporting requirements will lead to more consistency and comparability in non-financial reporting, which is crucial for a level playing field.

RWE welcomes the revision of the Non-financial Reporting Directive leading to the Corporate Sustainability Reporting Directive. Strengthening reporting requirements including relevant sustainability aspects will lead to more transparency in corporate reporting while allowing organizations and companies to follow a transition path to a sustainable and economic business model.

CDSB welcomes the publication of the Corporate Sustainability Reporting Directive. As highlighted by our latest research on the state of EU environmental disclosure in 2020, the current NFRD was not providing investors with the material climate and environmental information they need to assess and understand companies’ development, performance, position and impact.

stellungnahme Stellungnahme des Deutschen Gewerkschaftsbundes zum Richtlinienvorschlag der Europäischen Kommission über eine „Corporate Sustainability Reporting Directive“1 07.06.2021 1) Einleitung und zusammenfassende Hinweise Deutscher Gewerkschaftsbund Für den Deutschen Gewerkschaftsbund (DGB) und seine Mitgliedsgewerkschaften hat die nachhaltige Entwicklung in Deutschland, in Europa und weltweit einen hohen…

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The revision of the NFRD/CSRD should not go beyond the target. In line with the principle of proportionality, the requirements and scope must be tailored to the capacities of the various actors and their size. The need for new data and additional reporting is counterbalanced by a potentially enormous administrative burden, which runs counter to the objectives of sustainable finance.

Filed in German · English published by the European Commission

Europäische Kommission Grundsatzfragen WP Dieter Gahlen T. [phone removed] F. [phone removed] [email removed] 28. Mai 2021 Ga/TK Nachhaltigkeitsbezogene Unternehmensberichterstattung Richtlinienvorschlag der Europäischen Kommission "Corporate Sustainability Reporting Directive" Sehr geehrte Damen und Herren, wir bedanken uns für die Möglichkeit zur Stellungnahme zu dem Richtlinienvorschlag der Europäischen…

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Reclaim Finance notes that the proposal includes some very positive element: 1) The extension of the scope of the Directive to include all large companies - listed and non-listed. 2) A requirement to develop European sector specific mandatory sustainability reporting standards. 3) The confirmation of the principle of “double materiality”.

The Administrative Board of the Accounting Standards Committee of Germany (ASCG) has adopted four key messages on the proposed CSR-Directive. Standardisation: EU standards for sustainability reporting need a clear international orientation. Feasibility: The implementation of reporting obligations must be feasible, both in terms of content and application deadline.

WWF applauds the ambition the Commission has taken in this much awaited legislative proposal. More concretely, among very positive elements we see the following: 1. The extension of the scope of the Directive to include all large companies, both listed and non-listed which already makes a big difference in terms of the impacts large companies can have on people and planet.

In our 2020 position paper ‘Towards a global, investor focused standard setter for corporate non-financial reporting’, Eumedion advocated the establishment of an International Sustainability Standards Board (ISSB) under the auspices of the IFRS Foundation with the aim to develop high-quality international sustainability reporting standards (ISRS).

The following points are issues which EuropeanIssuers believes are necessary to address in the upcoming review of the Non-financial Reporting Directive (NFRD): • A harmonised non-financial reporting framework developed under EU leadership is needed to stop the proliferation of various public or private reporting initiatives which are not aligned and make reporting extremely time-consuming and confusing for…

25. February 2020 20/01219-4 son-dep Danish response to the Roadmap for the revision of the NonFinancial Reporting Directive (NFRD) We support the initiative of the Commission in the European Green Deal to evaluate the Non-Financial Reporting Directive (NFRD) and appreciates the opportunity to comment on the Commission’s roadmap.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ClientEarth’s response to the roadmap consultation for the inception impact assessment of the revision of the Non-Financial Reporting Directive ClientEarth is a non-profit environmental law organisation based in London, Brussels, Berlin, Warsaw, Madrid, New York and Beijing. Please do not hesitate to contact Tatiana Lujan ([email removed]) for further information on anything contained in this response.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Feedback on Revision of the Non-Financial Reporting Directive r3.0, a networked NGO focused on redesign for resilience & regeneration (founded by experts with experience leading the Global Reporting Initiative (GRI) and producing sustainability reports for GE, Siemens, Walmart, and others), supports Policy Option 3: Revise and strengthen the provisions of the NFRD.

Rethink Plastic Alliance’s response to the roadmap consultation for the inception impact assessment of the revision of the Non-Financial Reporting Directive 1 About Rethink Plastic Alliance Rethink Plastic is an alliance of leading European NGOs, with thousands of active groups, supporters and citizens in every EU Member State.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Climate Disclosure Standards Board (CDSB) would like to thank the European Commission for the opportunity to provide comments on the Inception Impact Assessment as regards the Revision of the Non-Financial Reporting Directive. it is clear that the current Non-Financial Reporting Directive does not fulfil its intended aims and outcomes and option 1. to continue the current approach is not a viable option.

The ETUC reiterates that the Non-Financial Reporting Directive does not provide the necessary framework to fulfill the needs of stakeholders (including workers and their representatives) for full, reliable and timely information on companies’ policies and impacts on the environment, workforce, society, human rights, bribery and corruption.

AFG, the French Asset Management Association, welcomes the future revision of NFRD in order to favour a sustainable, circular and low carbon economy. We see three main objectives in the revision of NFRD: - Reinforce the utility and the objective of the extra-financial reporting - Keep the proportionality of the approach for smaller stakeholders - Ensure the consistency within the European legislation (BMR, Taxonomy…

The International Association of Oil & Gas Producers’ (IOGP) member companies account for approximately 90% of oil and gas produced in Europe. IOGP welcomes the world’s ambition as laid out the framework of the Paris Agreement. There are many challenges on the road to meet this objective, and the energy transition will require significant investments, new technologies, effective policies and behavioural changes.

Enhancing the reliability of companies’ sustainability claims is key to respond to the investment community need for more and better non-financial information, to effectively manage financial risks from the environmental and social challenges we face, and to inform impact investment decisions.

The DNF Observatory (http://www.osservatoriodnf.it/en/) is delighted to have the opportunity to contribute to the Revision of the Non-Financial Reporting Directive by providing comments regarding the Inception Impact Assessments of the European Commission. Basing on the analysis of more than 400 non-financial declarations (NFDs) issued by the Italian companies since the enactment of Legislative Decree n.

The EACB welcomes the Commission initiative to amend the requirements in the Non-Financial Reporting Directive in order to ensure that investors and other interested parties have access to the information they need, while not imposing excessive reporting obligations on companies.

The revision of the Non-Financial Reporting Directive can be a step forward in making an assessment of the cost and benefit of the associated measures to the business fabric. In relation to the Roadmap, we would like to highlight the following comments to be considered: • In the section dealing with the problems of reviewing the application of the legislation, the consequences are not those caused to the business…

Filed in Spanish · English published by the European Commission

A Global Compact Network Spain apppreciates this opportunity to contribute its opinion on Inacceptance Impact Assessments of the revision of the Directive on non-financial reporting. An increasing number of different stakeholders are seeking financial information in order to make their decisions. For this reason it is important that the information is safe and comparable.

Filed in Spanish · English published by the European Commission

As Europe’s largest institutional investor (€10 200bn of assets under management), the insurance industry is in a unique position to help finance the transition to carbon-neutral, resource-efficient and more sustainable economies. The insurance industry is both an issuer and a preparer of non-financial information.

SMEunited contribution to the Inception Impact Assessment on the Revision of the Non-Financial Reporting Directive This position paper is a first reaction as a reply to the Inception Impact Assessment. SMEunited will reply more in detail on the public consultation launched on the 20th February 2020.

CSR Europe’s response to the Roadmap for the Revision of the Non-Financial Reporting Directive (2/2) Policy option 3 On ‘specifying in more details what non-financial info companies should report on’: • We would welcome a widening of the topics as long as it is material for the companies to report on and it does not turn into a tick box exercise.

CSR Europe’s response to the Roadmap for the Revision of the Non-Financial Reporting Directive (1/2) In relation to the policy options suggested by the European Commission for the Revision of the Non-Financial Reporting Directive, CSR Europe suggests the following: Policy Option 1: Yes, we believe that the Commission should continue its approach of non-binding guidelines because: • There is still a need to restate…

EuroCommerce welcomes the oppunturity to provide feedback regarding the Inception impact assessment on a revision of the Non-Financial Reporting Directive. The attached statement aims to summarise key points from the retail and wholesale sector on non-financial reporting and support the Commission’s work in revising the Non-Financial Reporting Directive.

• A harmonised non-financial reporting framework developed under EU leadership is needed to stop the proliferation of various public or private reporting initiatives which are not aligned and make reporting extremely time-consuming and confusing for corporates who are confronted with numerous questionnaires and ratings, based on different methodologies and definitions.

The NFRD should take th form of a Regulation, to ensure harmonization and efficiency. EU should start the work of standardizing the format and the structuring of companies’ ESG reporting, building on the existing market tested models and practices.

Contributing to defining a more robust framework for the quality and comparability of the non-financial reporting of listed companies is one of the AMF’s priority for action in 2020. Therefore, the AMF welcomes the opportunity to provide its thoughts and experience on non-financial reporting.

GRI encourages the EC to support the increased reporting of non-financial information to help progress the EU towards its sustainable finance ambitions, as set out in the Green Deal. We appreciate the opportunity to share our initial reactions towards the revision of the NFR Directive.

We are pleased to take the opportunity to communicate our thoughts on the revision of Directive 2014/95/EU within the framework of the consultation. First, the results of the study mentioned in section D should be evaluated.

French companies have been engaged for many years in putting CSR at the heart of their strategies and are considered world leaders on third-party verified corporate responsibility reporting. They present the highest level of non-financial information and can provide a legitimate and experienced-based contribution to the Commission’s work on the revision of the 2014 Directive.

European Commission Stockholm 27 February 2020 Inception Impact Assessment of the Revision of the Non-Financial Reporting Directive FAR, the Institute for the Accountancy Profession in Sweden, is responding to the Inception Impact Assessment of the Revision of the Non-Financial Reporting Directive.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Feedback of the German Sustainability Code Office on the review of the Directive 2014/95/EU towards the EU Commission 26.02.2020 The German Council for Sustainable Development (RNE) advices the German Government on topics regarding the sustainable development of this country. The Council maintains projects such as the German Sustainability Code.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Ecopreneur.eu welcomes the European Green Deal (EGD) including the importance attached to companies and financial institutions improving their disclosure of non-financial information so that investors are better informed about the sustainability of their investments.

The Commission has initially identified 3 policy options to review the NFRD. Repsol believes that NFRD should be revised and strengthen, modifying current non-financial reporting requirements in accordance with EU Commission’s option 3 taking into account the following requests: 1) Specifying in more detail what non-financial information companies should report: A reporting framework should help companies and…

The Industrial Minerals Association Europe (IMA-Europe) represents the European industrial minerals producers. Industrial minerals are indispensable to society in daily manufactured goods as well as green applications. They are increasingly essential to high-tech as well as environmentally friendly products and technologies such as wind turbines and photovoltaic panels.

We welcome the Commission's initiative to revise the NFRD, to achieve a greater degree of reliability, comparaibility of the information published. Regarding the Standards, we observe the need for globally accepted standards to guide the assurance process around Non-Financial Reporting.

The Swedish Agency for Growth Policy Analysis has conducted a project, “Can the financial markets’ sustainability assessments contribute to the green transition of the real economy, and if so - is there a role for the state?” In one analysis, attached, we evaluated the effect of Sweden´s implementation of the NFR-directive on sustainability reporting.

The World Benchmarking Alliance (WBA) welcomes the opportunity to respond to the Inception Impact Assessment regarding the Non-Financial Reporting Directive (NFRD) and recommends that the Commission pursue the third policy option identified within the Assessment – namely, to revise and strengthen the provisions of the NFRD.

Eumedion represents the interests of institutional investors in the field of corporate governance and sustainability. Its members are institutional investors that hold shares in Dutch listed companies. Eumedion is committed to promote good corporate governance and sustainability policies at Dutch listed companies and to promote engaged and responsible shareholdership by its members.

Thank you for the opportunity to comment on the roadmap. Indeed, we believe that a revision of the CSR Directive is urgently needed to address the weaknesses of today’s situation. In particular, the fight against corruption must be an integral part of any serious due diligence on both financial and non-financial aspects.

Filed in German · English published by the European Commission

Japan Business Council in Europe (JBCE) appreciates this opportunity to give a feedback on the inception impact assessment on the revision of the Non-Financial Reporting Directive. We would like to make comments on the following 7 points; 1. Non-financial reports (NFR) are tools, through which companies and stakeholders including investors can exchange on value-creating processes.

The French Banking Federation (FBF) strongly supports the European Commission initiative to improve the disclosure of non-financial reporting. Financial institutions are both issuers (Non-Financial Reporting Directive requirements) and users (Taxonomy, Disclosure, guidelines on NFRD regarding climate-related information) of non-financial data.

The Global Legal Entity Identifier Foundation (GLEIF) is pleased to provide comments to the European Commission on the Revision of the Non-Financial Reporting Directive Roadmap. GLEIF will focus its comments on the use of the Legal Entity Identifier (LEI) in the consultation. Please kindly see the attachment for GLEIF's response. Submitted by: [name removed], CEO GLEIF [email removed]

Non-financial reporting directive – Federation of Finnish Enterprises feedback The Federation of Finnish Enterprises (FFE), representing 115 000 small and medium-sized enterprises of Finland would like to express its views on the initial impact assessment regarding the non-financial information reporting directive (NFRD).

Dear Sirs, ASSIREVI – the Italian Association of Audit Firms - is pleased to have the opportunity to provide some comments to your document “Inception Impact Assessment”. ASSIREVI believes the Non Financial Reporting Directive (NFRD) represents the first step aimed at implementing non financial information and disclosure culture all over Europe and appreciates any further developments that will be achieved in this…

Health Care Without Harm (HCWH) Europe welcomes and supports the revision of the Non-Financial Reporting Directive and provides feedback to ensure that the future legislation contributes to the sustainable development agenda. The NFRD can support increased green investment, sustainable public procurement, and responsible consumption. Our detailed contribution can be found in the PDF attached.

The network of Chambers of Crafts and Crafts assists and represents in France and in Europe 1,3 million craft enterprises and 3,1 million assets embedded in the local economy. The industrial sector is made up of 75 % of the artisanal firms which constitute the subcontracting chain on which the large European companies are based.

Filed in French · English published by the European Commission

The NFRD has been in force just a short time. The first reports based on the directive were published in 2018. Amending existing legislation especially in this case, when it has been in force for just couple of years, seems too bureaucratic and heavy and going against the principles of better regulation.

We would like to thank you for the opportunity to provide an input for the review of the non-financial reporting Directive. In Denmark, we are generally very interested in comparable reporting between countries. It is important for businesses that cross borders, but also for smaller businesses, so there is no imbalance which creates distortions of competition.

Filed in Danish · English published by the European Commission

Generally, we believe that before deciding on the appropriate policy tool, any perceived shortcomings of the NFRD need to be assessed against whether those deficiencies can indeed be addressed appropriately by any of the three policy tools.

20 February 2020 ecoDa’s Reaction to the DG Fisma’s Inception Impact Assessment on the Non-Financial Reporting Directive DG FISMA has published an Inception Impact Assessment on the Non-Financial Reporting Directive and has left it for comments by February the 27th.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

With more than 10 billion euros yearly turnover, 45.000 staff members and 11 million people protected, Groupe Vyv, founded in 2017, is the leading French player in health insurance and the main national operator of care and support service.

The European Public Real Estate Association (EPRA) is the voice of Europe's listed real estate companies that derive income from the ownership, trading and development of income producing real estate assets. With more than 270 members (companies, investors and their suppliers), EPRA represents over 450 billion EUR of real estate assets (European companies only) and 94% of the market capitalisation of the FTSE EPRA…

The Finnish forest industry is committed to sustainability and with our renewed sustainability commitments spanning to the year 2025 we aim to demonstrate leadership and continuous improvement in sustainability. Thus, the industry has supported the top-level environmental objectives enshrined in the EU's framework to facilitate sustainable investment.

As representatives of the German fund industry, we consider it essential to obtain reliable, standardised and comprehensive information from companies on sustainability-relevant matters. Asset managers and institutional investors will only be able to pay due consideration to sustainability aspects when taking investment decisions if such information is readily available and comparable across different companies and…

While it may be argued that public reporting would incentivise companies to improve business practices, research suggests that non-financial disclosure has little to no effect on decision making to reduce adverse impacts on society. Moreover, it has even been found to be used by companies to reduce exposure to critique or social accountability.

Key requirements: • No extension of the scope of the NFRD to SMEs • Create fair voluntary disclosure frameworks for SMEs @-@ Explanation: SMEs take their collective responsibility seriously and are strongly committed to sustainability on a traditi-on-line basis. Craft businesses are an essential pillar of sustainability, as they strengthen regional economic cycles, repair, advise, maintain, plan and develop.

Filed in German · English published by the European Commission

The EFAA Memorandum for Elections to the European Parliament 2019 - SMPs Supporting SMEs for Europe (see https://www.efaa.com/cms/upload/efaa_files/pdf/events/2019_brussels/20190219-EFAAEPPrioritiesforSMEs-FINAL_for_web.pdf) included priority “4) Promote Contribution of SMEs to a More Sustainable Economy” and specifically requested “the introduction of measured and proportionate requirements for SMEs to report on…

Dear Sirs/Mesdames, We are taking this opportunity to share with you our considerations on the review of Directive 2014/95/EU. Furthermore, we are very interested in the evolution of non-financial reporting. We believe that the provision of high-quality sustainability information is an important issue.

Dear Sir or Madam, We appreciate the opportunity to give an early feedback on the Commission´s Inception Impact Assessment concerning its initiative with regard to updated rules on non-financial reporting by large companies.

The Commission presents three options for the further development of the Non-Financial Reporting Directive. The Deutscher Raiffeisenverband is of the opinion that the current rules are sufficient. They provide sufficient guidance for workable implementation in individual companies. Against this background, the Association is in favour of Option 1.

Filed in German · English published by the European Commission

We welcome the opportunity for early feedback on the Commission’s reflection on a revision of the Non-financial Reporting Directive. Over the last decade, the number of signatories to the Principles for Responsible Investment has risen from under 100 to over 2,500 (https://www.unpri.org/directory/).

WWF would definitely choose option 3. Sector-specific Key Performance Indicators (KPIs) Problem: The NFRD fails to provide any granular, sector-specific guidance as to what they should be trying to illustrate. Problematically, a ‘one size fits all’ approach does not work with sustainability indicators.

The Commission describes three options for the further development of non-financial reporting. We support the first option (continue the current approach). The second (explore the use of standards) and third (revise and strengthen the provisions) options must be rejected in the light of the principle of subsidiarity and appropriate and cost-effective regulation.

The environmental impact of large companies - especially in the manufacturing and commercial sectors - is significant. Their choice of logistics practices and freight transport services has an immense impact. Energy efficiency, carbon-, pollutant- and noise emissions should be used as the major indicators.