EU Environmental Taxonomy: ASCG comment letter submitted to the European Commission

On 3 May 2023, the ASCG submitted its comment letter on the consultation of two delegated regulations on the EU Environmental Taxonomy Regulation (Regulation (EU) 2020/852).

In its comment letter, the ASCG focuses on the reporting requirements for non-financial undertakings and thus on the revisions to Delegated Regulation (EU) 2021/2178. In the comment letter, the ASCG repeatedly advocates clarifications and simplifications. In addition, the following overarching issues are addressed:

• the establishment of a dedicated communication channel so that undertakings can communicate the addition of new activities and the revision of existing requirements to the European Commission in a standardised way,
• clear requirements that leave little room for interpretative uncertainty, and
• early announcement of new requirements and clarifications to improve predictability for preparers of disclosures.

The ASCG will continue to follow the developments on the EU environmental taxonomy. In the past, we have held eleven user forums on the EU Environmental Taxonomy with our member organisations, and the user forums are scheduled to continue this year. The issues and solutions discussed in the user forums have been submitted to the European Commission.

Some of the issues raised in the submissions are also addressed in the FAQ documents published by the European Commission. Additional information and a ASCG briefing paper on reporting requirements can be found on the relevant ASCG project page.