CSRD INSIGHTS
CSRD Hub Newsletter #5
June 2024
CSRDCS

From the Trenches

 

As companies make their way through their first double materiality assessments, many are turning to the task of disclosure, beginning with the ESRS 2 disclosures.

 

As a quick reminder, the ESRS 2 disclosures are required regardless of materiality. They cover a number of items, from the basis for preparation for the sustainability statement (BP), to broad sustainability governance (GOV) to sustainability in the strategy and business model (SBM), to management of material IROs (IRO). Another category includes the minimum disclosure requirements (MDRs) which are to be disclosed for each material topic.

 

Remember, too, that several topical standards also have ESRS 2 disclosures, such as E1 GOV-3. With the exception of topic-specific SBM-3 disclosures, these are to be included in the General Information section, alongside other ESRS 2 disclosures.

 

And of course, there are the Application Requirements, many of which are mandatory, and all of which need to be considered when completing the ESRS disclosures, whether ESRS 2 or topical disclosures.

 

Are we having fun yet?

 

Because so many companies are tackling these cross-cutting ESRS 2 disclosures, we thought a few examples of how companies are starting to structure their reports around them would be helpful.

 

Keep in mind these reports are voluntarily focusing on ESRS before it is required, so a little grace is in order if there are remaining gaps to fill.

 

Examples:

 

• Schibsted. Schibsted is a Nordic-focused digital media company. Their sustainability statement, beginning on page 13, is structured directly around ESRS. The GOV-4 (due diligence) disclosure is well done and worth a read.

• CTP. CTP, a Dutch company focused on business park development across Europe, has incorporated ESRS references throughout their report. Their sustainability statement (beginning on page 84) does a nice job covering ESRS content with tags, although the sections are numbered according to the broader report structure. Basis for Preparation (BP) is particularly well done.

• Jeronimo Martins. Jeronimo Martins, the Portuguese food and retail company, includes a detailed table structured around ESRS disclosures with further cross-referencing to GRI information. See pages 407-430). While some of the information is missing, the structure is helpful inspiration for companies who are gathering this information. A shorter web-based table of indicators is available online.

 

We keep a running list of reports that reference ESRS or have begun alignment. Reach out if you have any questions or are looking for specific disclosure examples, and please pass along any that you find helpful.

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EFRAG/CSRD UPDATES

 

EFRAG publishes updated implementation guidances

 

The first three ESRS Implementation Guidance documents include EFRAG IG Materiality Assessment, EFRAG IG 2 Value Chain and EFRAG IG 3 ESRS Datapoints. 

 

These documents are non-authoritative and support implementation.

 

Link

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As a side note, our Double Materiality Tool already incorporates the EFRAG guidance.

 

 

EFRAG releases new ESRS Q&A technical explanations

 

EFRAG releasd a batch of 68 Explanations to respond to stakeholders’ technical questions on the ESRS, which includes 12 Explanations already released on February 5 and 12 Explanations released on March 1.   

 

The Explanations are grouped in chapters, including Cross-cutting, Environment, Social, and Governance and their Disclosure Requirements, following the ESRS’ architecture.  

 

EFRAG will continue releasing Explanations following its due process.

Link

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Latest updates to CSRD Trasposition Tracker

 

Eight countries have adopted legislation implementing CSRD (at least in part), including Czechia, Denmark, Finland, France, Hungary, Romania, Slovakia and Liechtenstein, according to the Ropes & Gray April updates to its CSRD Transposition Tracker.

 

Countries continue to make progress towards implementation. Besides the eight countries, which have adopted legislation implementing CSRD (at least in part), eight have proposed legislation and another seven have held consultations.

 

Link

 

OTHER SUSTAINABILITY NEWS

 

GRI and IFRS collaborate to deliver full interoperability 

 

The increased collaboration will optimize how GRI and ISSB Standards can be used together to facilitate reporting on an organization’s impacts, risks and opportunities, including risks that arise from the organization’s impacts.

 

The International Sustainability Standards Board (ISSB) and the Global Sustainability Standards Board (GSSB) have committed to jointly identify and align common disclosures that address information needs under the distinct scopes and purposes of their respective standards, for both thematic and sector-based standard setting. An initial outcome of the collaboration will involve a methodology pilot building on the recently published GRI 101 Biodiversity Standard and the ISSB’s upcoming project on Biodiversity, Ecosystems and Ecosystem Services.

 

The ISSB and the GSSB will continue to make decisions separately in accordance with their established standard-setting due processes, including public consultation in respect of any proposed amendments to their respective standards regarding the alignment of common disclosures.

 

Link

 

The Council formally adopts the corporate sustainability due diligence directive (CSDDD)

 

This is the last step in the decision-making procedure. Member states will have two years to implement the regulations and administrative procedures to comply with this legal text.

 

The directive introduces obligations for large companies regarding adverse impacts of their activities on human rights and environmental protection. It also lays down the liabilities linked to these obligations. The rules concern not only the companies’ operations, but also the activities of their subsidiaries, and those of their business partners along the companies’ chain of activities.

 

ESMA published  guidelines on funds’ names using ESG or sustainability-related terms. 

 

The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, published the final report containing Guidelines on funds’ names using ESG or sustainability-related terms. 

 

The objective of the Guidelines is to ensure that investors are protected against unsubstantiated or exaggerated sustainability claims in fund names, and to provide asset managers with clear and measurable criteria to assess their ability to use ESG or sustainability-related terms in fund names.

 

The Guidelines establish that to be able to use these terms, a minimum threshold of 80% of investments should be used to meet environmental, social characteristics or sustainable investment objectives. The Guidelines also apply exclusion criteria for different terms used in fund names: 

 

Link