ASCG publishes draft comments on the EFRAG consultation of ESRS

On 19 July 2022 the ASCG published its draft comments on the exposure drafts of European Sustainability Reporting Standards (ED ESRS). The draft comments include responses to all consultation surveys:

• Consultation survey 1A: Architecture
• Consultation survey 1B: Implementation of CSRD principles
• Consultation survey 1C: Exposure Drafts content
• Consultation survey 2: ESRS implementation prioritisation / phasing-in
• Consultation survey 3A: Adequacy of Disclosure Requirements – Cross cutting standards
• Consultation survey 3B: Adequacy of Disclosure Requirements – Environmental standards
• Consultation survey 3C: Adequacy of Disclosure Requirements – Social standards
• Consultation survey 3D: Adequacy of Disclosure Requirements – Governance standards

In addition, the ASCG published a document (only in a German version) explaining its understanding of the survey questions. The draft comment may be subject to changes. EFRAG will receive the final comments by the end of the consultation period on 8 August 2022 at the latest.

Georg Lanfermann, President of the ASCG, commented: “The scope, complexity and tight timeframe of the ESRS consultation is currently challenging for many stakeholders in Germany. With the publication of the draft comments of the ASCG, we want to offer German stakeholders orientation and technical input for their own comments. In particular, the Sustainability Reporting Technical Committee and the ASCG staff have done a great job in the past weeks.”

Background: The ESRS consultation started on 29 April 2022 with the publication of the ED ESRS, which will end on 8 August 2022. According to the proposal for an EU Corporate Sustainability Reporting Directive (CSRD) of April 2021, the ESRS are to be developed by EFRAG and specify the reporting obligations on sustainability reporting included in the EU Accounting Directive. The ESRS will be mandatory for approximately 15.000 companies in Germany. In the meantime, a political agreement on the CSRD was reached in the formal trilogue meeting on 21 June 2022. A working version of the final CSRD was published on 30 June 2022.

The ASCG provides an overview in German of both the ED ESRS and the CSRD (both documents only in a German version)