ASCG comments on Sustainable Finance Committee’s Interim Report

ASCG considers the Sustainable Finance Committee’s Interim Report as a major contribution to the current political and public discourse on the establishment of a sustainable financial sector. The Committee was appointed by the German Federal Government and advises the Government on the preparation and implementation of its sustainable finance strategy. In its Report, the Committee covers 53 recommendations for discussion.

ASCG’s Comment Letter focuses on aspects of non-financial corporate reporting. The Committee considers a good data basis to be crucial for a resilient financial sector supportive of the intended transformation. Accordingly, the report contains several recommendations for the further development of non-financial corporate reporting.

In its Comment Letter, ASCG addresses the following core positions:

• Deeper embedding of the discussion in the European and international context: The further development of non-financial corporate reporting obligations should take place at European level and in the context of the CSR-Directive. Relating to the standardisation of non-financial corporate reporting, ASCG prefers an international approach based on the model of the International Accounting Standards Board and the International Financial Reporting Standards.
• Preference for directly addressing regulatory affairs: Transformation paths to implement sustainability targets should be directly addressed. This means that the expectations and requirements should basically be addressed directly to the companies. Accordingly, ASCG does not support an expansion of the established and proven understanding of the objectives of corporate reporting (information and stewardship) by politically motivated aspects.
• Stronger recourse to financial reporting expertise: Financial and non-financial issues are not unrelated; they are linked with each other. This connectivity has to be taken into account appropriately. ASCG points out that this must not be misinterpreted in such a way that the established financial reporting according to IFRS is undermined with arguments of a sustainable financial strategy.
• Data quality and reliability: The report lacks a position on the auditability of non-financial information. ASCG recommends the inclusion of this central aspect of corporate reporting.
• Consideration of the current challenges caused by the Covid-19 crisis: At present, companies are extensively involved in handling with the extraordinary challenges resulting from the Covid-19 crisis.

ASCG reminds for this fact that has to be considered in the further work of the Committee.
Detailed explanations on the positions as well as detailed comments on the respective recommendations addressed in the Report are available here.