Joint investor statement on the draft European Sustainability Reporting Standards (ESRS)

IIGCC has joined a coalition of major users of sustainability data in publishing joint recommendations on the ESRS delegated act. We welcome the Commission's progress on simplification, but we believe important gaps remain that could weaken comparability and the decision-usefulness of sustainability reporting. 

Key asks:

• Preserve quantitative and qualitative disclosures on anticipated financial effects so investors can link sustainability issues to future financial impacts.
• Retain double materiality and the fair-presentation principle to keep reports balanced and decision-useful.
• Maintain the ESRS structure and avoid further cuts to essential data points that support comparability and transition assessment.
• Limit broad phase-ins and reliefs by requiring clear eligibility, mandatory justification and timebound phase-outs.
• Align the value-chain cap with voluntary standard modules to avoid narrowing information availability or shifting reporting to bespoke questionnaires.

IIGCC consultation response

We have also published our own response to the Commission's ESRS consultation, setting out nine targeted amendments to strengthen investor-relevant disclosures while supporting simplification. A summary of our response can be accessed here.