12 March 2021
Annex 1:
Companies’ access to “upstream” data
The increased demands and legal requirements for companies to disclose
on environmental, social and governance (ESG) issues has increased calls
by companies for common standards and methods, tools and better access
to data, which they need to be able to disclose in a transparent, structured
and standardized manner. The establishment of a European Single Access
Point to companies’ non-financial
information can give the financial sector
better access to ESG data.
However, at the same time it is important to point out that the ESAP only
address the “downstream” part of the chain of ESG data. With the expand-
ing variety of ESG issues that companies are expected and required to re-
port on, collecting the needed data to do so, is an increasingly complex and
demanding task, requiring the use of considerable resources by companies.
While the proposed ESAP will give better access to information for the
financial sector, more is needed to ensure that companies are able to dis-
close reliable information in the first place, as the information requested is
not information that companies hold today.
The Danish government therefore stresses that similar initiatives are
needed aiming at giving better access to the data needed by non-financial
companies. One such example of data needed, is data on direct and indirect
emissions of CO2 equivalents of a wide range of both energy and non-en-
ergy resource consumption throughout value chains, i.e. allowing compa-
nies to assess their carbon footprint in scopes 1, 2 and 3 of the Green House
Gas Protocol. This is just one example of data that companies currently
struggle to access.
Just as the Commission has proposed an ESAP to increase data access, the
Danish government calls on the Commission to thoroughly map compa-
nies’ need of external data and to bring
forward proposals aimed at giving
companies better access to the external data needed for ESG reporting.
Failure to ensure
companies’ access to data in this “upstream” part of the
data chain runs the risk that neither non-financial companies or financial
companies will be able to fulfill the reporting requirements under the EU
taxonomy regulation or the Disclosure regulation in a meaningful way.
This will have negative implications for the overall efforts of achieving the
aims of the sustainable finance strategy and the European Green Deal.
While we understand that this is outside the scope of ESAP, we recommend
the Commission to look into this important issue, for instance in the context
of the establishment of a Green data space.