The Association understands the need to postpone the introduction of the CSRD in phases. Legal uncertainty for companies in the three implementation phases must be avoided. That is why the Association is asking for pragmatic recommendations for companies that already report (phase 1) to prevent them from incurring additional costs for rules that will soon no longer apply.
Reports with impact
Furthermore, the Association states that financial enterprises report on the same matters as non-financial enterprises. At the same time, it is essential for reliable sustainability data that the business community aligns reporting obligations. Especially now that the Omnibus proposals will drastically reduce the number of companies that have to prepare reports.
The risk is that companies with material impact no longer have to draw up a report, which leads to poorer data quality and thus has consequences for the climate objectives to be achieved. That is why the Association argues for an increase in the number of companies with reporting obligations, but on the condition that the number of data points to be reported is drastically reduced in order to keep the administrative burden low. In combination with a higher materiality threshold, companies are prevented from having to report on too many activities.
Avoid overlap in legislation
Avoid overlap in legislation by better aligning definitions and scope within the CSRD, CSDDD and Taxonomy. Different definitions lead to duplicate reporting. Also include the existing reporting obligations in Solvency II and the Sustainable Finance Disclosure Regulation (SFDR) in the streamlining process, otherwise the regulations will remain unnecessarily complex and the intended 25% reporting reduction will not be achieved.
Stimulate transition financing
Encourage transition financing within the Taxonomy so that insurers have sufficient guidance for investment decisions. A step in the right direction is the possibility in the Omnibus package for companies to report on activities that are already partly aligned with the Taxonomy.
If the Commission takes these points into account, the EU Omnibus package can contribute to reducing the regulatory burden for entrepreneurs. Without compromising the ambition to achieve the existing climate targets.