Public consultation on the first set of Draft ESRS

About the Draft European Sustainability Reporting Standards

The European Commission’s proposal for a Corporate Sustainability Reporting Directive (CSRD) envisages the adoption of EU Sustainability Reporting Standards (ESRS).
 
In this context, EFRAG was requested in a letter from Commissioner McGuinness to provide Technical Advice to the European Commission in the form of fully prepared draft standards and/or draft amendments to Sustainability Reporting Standards.
 
The proposal for a CSRD requires that EFRAG’s Technical Advice is prepared with ‘proper due process, public oversight and transparency, and with the expertise of relevant stakeholders, and it is accompanied by cost-benefit analyses that include analyses of the impacts of the Technical Advice on sustainability matters’, contributing to the delegated acts through which the ESRS will be adopted in the EU.
 
In order to meet the ambitious deadlines for submitting the first set of draft ESRS to the European Commission by November 2022 and to benefit from the longest public consultation period possible, it was critical that the public consultation on the Exposure Drafts 5 (EDs) of the first set of ESRS be launched as soon as possible.  In this context, the EFRAG SRB decided to launch the public consultation on the basis of the EDs prepared under the sole responsibility of the PTF-ESRS.
 
In this context and following the EFRAG's Due Process Procedures on EU Sustainability Reporting Standard-Stetting , which stipulate the requirements to be followed in its role as technical advisor to the European Commission in the preparation of draft ESRS or draft amendments of ESRS, the PTF-ESRS hands over its Draft ESRS for public consultation with deadline of 8 August 2022.
 
These EDs correspond to the first set of standards required under the CSRD proposal and cover the full range of sustainability matters: environment, social, governance and cross-cutting standards.
 
The EFRAG SRB and the EFRAG SR TEG will consider the EDs in parallel with the public consultation and following the handover by the PTF-ESRS. Together with the input and results from the public consultation, the EFRAG SRB supported by the EFRAG SR TEG will agree the final first set of draft ESRS to be submitted to the European Commission.

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Public consultation and responses received

On 29 April 2022, EFRAG launched a public consultation on the Draft ESRS EDs, with a deadline of 8 August 2022. A broad spectrum of stakeholders responded to the public consultation, mostly through the two-part online survey. 

The EFRAG Sustainability Reporting Board (EFRAG SRB) and EFRAG Sustainability Reporting Technical Expert Group (EFRAG SR TEG) consider all comments received, as required by the EFRAG Due Process Procedures. The resulting first set of Draft ESRS will then be handed over to the European Commission in November 2022 to be considered for adoption adoption by way of delegated acts at a later stage after the European Commission’s process and consultations.

.All comment submissions received in response to the public consultation through the two-part online survey, to be taken into consideration by EFRAG SRB and EFRAG SR TEG, are made available through the links below (please note it may take some time for contributions to display):

• Survey 1 - Overall ESRS exposure drafts relevance (Architecture, Implementation of CSRD principles, Exposure Draft content, Implementation prioritisation)

• Survey 2 - Adequacy of disclosure requirements (cross-cutting and topical standards)
  

It should be noted that the above data is as submitted by respondents to the consultation and may contain a limited number of duplicate or blank submissions.

The public consultation was organised to receive feedback from constituents on three key aspects of the EDs, organised in a chapter menu as follows:

(1) Overall substance of the Exposure Drafts (survey 1)

1A. Architecture

1B. Implementation of CSRD principles

1C. Exposure Drafts content

(2) ESRS Implementation prioritisation / phasing-in (survey 1)

(3) Adequacy of Disclosure requirements (survey 2)

3A. Cross cutting standards

3B. Environmental standards

3C. Social standards

3D. Governance standards 

EFRAG did also received comment letters that did not address the specific aspects covered by the questions listed in the online survey:

• Comment letters uploaded to online survey
  
  
• Additional comment letters submitted to EFRAG

• Comments received after 8 August 2022 are available here.   
  

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Outreach events

During the public consultation period, EFRAG organised 16 outreach events in several EU countries to engage closely with stakeholders and get feedback on the Draft ESRS EDs. These outreach events attracted significant interest with close to 5000 registrations overall.

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