EBF RESPONSE PAPER

EBF response to the EC consultation on ESRS Set 1

BRUSSELS, 6 July  2023 – The European Banking Federation welcomes the European Commission’s efforts to further enhance the European Sustainability Reporting Standards (ESRS) developed by the EFRAG in the attempt to reduce reporting burdens for undertakings and to increase interoperability with the global standards.

With our response to the European Commission’s consultation on the Set 1 of the ESRS, we share our feedback to further enhance the standards and foster the cohesiveness and consistency of the overall sustainable finance framework.

While the European Commission has made various positive proposals to simplify and reduce the burden for reporting entities, the removal of mandatory disclosures under the ESRS will not alleviate burdens equally amongst stakeholders. Financial institutions will nonetheless be required to disclose information about their clients under other existing reporting requirements (e.g., Pillar 3 ESG, the Sustainable Finance Disclosure Regulation) and will request such data bilaterally. This will only increase the burden for all stakeholders involved, while contradicting the overall purpose and spirit of the Corporate Sustainability Reporting Directive, and that is coherence with other Union law, but most importantly increasing the availability of sustainability data.

For more information:

Alexia Femia, Policy Adviser – Sustainable Finance, a.femia@ebf.eu

x

About the EBF:

The European Banking Federation is the voice of the European banking sector, bringing together national banking associations from across Europe. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.