EBF POSITION PAPER
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Proposal for the Corporate Sustainability Reporting Directive: EBF position

BRUSSELS, 14 September 2021 – Please find below a few key points of the EBF’s position in relation to the Commission’s proposal:

• Banks particularly welcome the extended scope of the proposed Directive, which would cover all large undertakings, as well as listed small and medium-sized enterprises. This should, however, be accompanied by a close assessment regarding the feasibility of the requirements being legislated. Companies will need enough time to adapt their reporting processes to the new complex requirements. Similarly to the treatment envisioned for non-financial undertakings, we invite the Commission to, moreover, closely assess the need for an appropriately defined category for small and medium-sized credit institutions, for which a simplified reporting standard should be contemplated.
• The EBF proposes to further assess whether companies in high-risk sectors (e.g. mining, chemicals, etc) should be subject to mandatory reporting requirements regardless to size and to whether they are listed or unlisted.
• It is important to ensure that the simplified reporting standard for listed small and medium-sized enterprises be ready within an adequate timeframe as to ensure that reporting requirements emanating from larger undertakings would be standardised, coherent and comparable, as some of these companies will be required to start reporting already as of 2023 as a part of the value chains of large undertakings (regardless of the phase-in period which will allow them to report starting in 2026).
• Banks support the intention to ensure digital tagging (aligned with the timeline for the creation of the ESAP). On the other hand, concern has been expressed regarding the complexity linked to the use of the ESEF format, which has posed challenges even to large listed companies. With the extension of the scope, it will be essential to closely explore solutions to support undertakings transitioning to the ESEF format.
• Member States should maintain the discretion to allow for all CSRD-mandated reporting to be part of the management report, or to be separate. Sustainability disclosures should be produced in a reader-friendly format that would be understandable for all stakeholders, including non-specialists. Mandatory inclusion in the management report may lead to an overcomplicated format.

For more information:

Denisa Avermaete, Senior Policy Adviser, Sustainable Finance, d.avermaete@ebf.eu
Eleni Choidas, Policy Adviser, Sustainable Finance, e.choidas@ebf.eu
Alexia Femia, Financing Growth, a.femia@ebf.eu

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About the EBF:
The European Banking Federation is the voice of the European banking sector, bringing together 32 national banking associations in Europe that together represent a significant majority of all banking assets in Europe, with 3,500 banks – large and small, wholesale and retail, local and international – while employing approximately two million people. EBF members represent banks that make available loans to the European economy in excess of €20 trillion and that reliably handle more than 400 million payment transactions per day. Launched in 1960, the EBF is committed to a single market for financial services in the European Union and to supporting policies that foster economic growth.