Consultation on the amendment of the ESEF-RTS: ASCG comment letter submitted

On 31 March 2025, the ASCG submitted its comment letter (see letter with the same content) on the consultation on the amendment of the Regulatory Technical Standards (RTS) of the ESEF Regulation (Delegated Regulation (EU) 2019/815) to ESMA.

The proposals on electronic sustainability reporting are generally welcomed in the comment letter as the ASCG supports the equal treatment of financial and sustainability reporting with regard to digitalisation. However, we believe it is necessary to carry out a comprehensive review and a cost-benefit analysis before adopting detailed requirements for electronic sustainability reporting. Undertakings should not be required to apply granular mark-up rules if the associated costs do not justify the added value for users of sustainability reports. We are sceptical that the likely costs of the proposals are justified.

With regard to the proposals for electronic financial reporting, while we agree with the problems described in the consultation paper, we do not agree with the conclusion that the proposed revision of the mark-up rules for the notes to IFRS consolidated financial statements is necessary. In particular, we doubt whether users of financial reports actually use the detailed marking up of the notes to the consolidated financial statements in this level of detail. We therefore request that ESMA, as a first step, conduct a comprehensive review to determine whether the ESEF is still fit for purpose and why ESEF reports are not used by users of financial reports. On the basis of such a comprehensive review, targeted proposals for improvement can then be developed in a second step, which are tailored to the specific needs of users and whose costs are justified.

ESMA will review the feedback on the consultation in the second quarter of 2025. A final report is to be issued in the third quarter of 2025 and the final RTS submitted to the European Commission.

In response to the CSRD provisions on digital sustainability reporting, the ASCG formed a working group with XBRL Germany, which began its work on 10 January 2023. On 8 April 2024, the ASCG submitted a comment letter to EFRAG on the draft XBRL taxonomies. On 8 August 2024, the ASCG published a briefing paper on digital sustainability reporting (in German only), which takes into account the publication of the government’s draft implementation law for the CSRD on 24 July 2024. Finally, the ASCG has been organising a user forum on digital financial reporting in accordance with the ESEF Regulation since 2019, which exclusively offers ASCG member companies and associations an insight into current developments and serves as a platform for discussing implementation issues.