EUU, Alm.del - 2021-22 - Bilag 688: Høringssvar vedr. virksomheders bæredygtighedsrapportering

Europaudvalget 2021-22
EUU Alm.del Bilag 688
Offentligt

08 August 2022

2022 - 4706

otfruh

Danish Government response to the EFRAG public hearing on the

draft standards to the Corporate Sustainability Reporting Directive.

First of all, the Danish Government would like to thank EFRAG for the

comprehensive work on drafting the coming European sustainability stand-

ards linked to the Corporate Sustainability Reporting Directive (CSRD).

We see the standards as an effective tool to ensure transparency and com-

parability of sustainability reporting, thereby supporting the transition into

a sustainable economy. It is furthermore essential to create transparency

and comparability regarding sustainability and make rules that is fit-for-

purpose and adds value for the users of the data.

The European Sustainability reporting standards will not only have a big

impact on sustainability reporting and the availability of sustainability in-

formation, but ideally also facilitate a market-driven transition to a sustain-

able economy, thereby having a positive impact on the transition of the

European companies’ business models and strategies towards a more sus-

tainable future.

The Danish Government supports EFRAG in establishing a relevant set of

standardized ESG indicators. The set of ESG disclosures must be compat-

ible with the needs for information from the financial market participants

as required by the Disclosure Regulation and the Taxonomy Regulation,

thereby providing companies, investors and other stakeholders with struc-

tured data to make informed choices on sustainability challenges.

Ensuring value creating sustainability reporting

The Danish Government agrees that both investors and other stakeholders

are asking for more relevant, reliable and comparable information. Report-

ing on relevant ESG

KPI’s is essential for a fair, balanced and understand-

able report and this will positively contribute to transparency.

It must be ensured that the standards generate value for both the users of

sustainability information and the companies reporting. It is important to

ensure that the disclosure requirements achieve the overall goal while al-

lowing the reporting companies and authorities a swift and efficient im-

plementation as well as avoiding information overload for investors, con-

sumers and other stakeholders from too much data.

EUU, Alm.del - 2021-22 - Bilag 688: Høringssvar vedr. virksomheders bæredygtighedsrapportering

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The transition of sustainability reporting

The CSRD will change the annual reports radically, as sustainability infor-

mation will be a more significant part of the annual report. It must be en-

sured that the objective of this transformation of sustainability reporting is

operable for many users of the data. Being sustainable must become a com-

petitive advantage for our European companies and a top priority for all

companies.

The disclosure requirements must be executable for the reporting compa-

nies, and at the same time help the companies and incentivize them in lead-

ing the way for a green and sustainable transition. By starting with an exe-

cutable amount of key disclosure requirements we ensure that the quality

of the reporting is a good starting point for further development of sustain-

ability reporting. This will increase the effect of the reporting scheme and

give the whole value chain time to adapt to the green and sustainable tran-

sition. Over time, the reporting can be extended.

It is also essential to assess whether all of the disclosure requirements are

relevant for the stakeholders and for all companies in scope also keeping in

mind that not all companies have the same kind of resources available. We

therefore underline the importance of evaluation on whether some require-

ments are more relevant in sector-specific standards. To ensure that the

purpose with the CSRD is met, it is important that companies can imple-

ment key comparable figures for sustainability matters relatively quickly.

Therefore, a stepwise introduction of standards where the most important

are introduced first should be considered. This approach would also benefit

SME’s that will be indirectly affected by the regulation due to their role as

data providers to undertakings within the scope of CSRD.

We request EFRAG to revisit the disclosure requirements regarding gov-

ernance as the current draft has requirements that are already covered by

the accounting directive and thus creates a parallel set of rules which must

be avoided.

After the summer break we will come back to you with a more technical

annex elaborating on our position regarding the specific content of the dis-

closure requirements.

We look forward to following the future work on the standards and we

stand ready to share our Danish experience in order to ensure an effective

market-driven transition to a sustainable economy.