Consultation response from the Ecological Accounting Chair – Delegated Act on European Sustainability Reporting Standards (set 1)
Thursday 13 July 2023
Consultation response from the Ecological Accounting Chair - Delegated Act on European Sustainability Reporting Standards (set 1)
Author: Nicolas Zoubritszki, for the Ecological Accounting Chair
With contributions from : Clément Boyer, Clément Morlat, Aurélien Oosterlinck, Alexandre Rambaud
Summary: The CSRD Directive imposes increased transparency requirements on the socio-environmental reporting of major European companies, based on the principle of double materiality. In this response to the European Commission’s public consultation on the adoption of the first set of ESRS standards, we offer some food for thought on how to "land" this transparency requirement, and put it at the service of real corporate accountability, in line with the concerns of our time.
To this end, we propose that the definition of socio-environmental materiality be aligned, by analogy, with the definition of financial materiality, which would justify the inclusion of minimum sustainability analysis criteria, common to all companies and presumed "material" for all stakeholders.
In addition, the preservation of human and environmental capital confronts companies with new types of financial obligations, which could be reported alongside "risks" and "opportunities". The link between socio-environmental materiality and financial materiality could thus be refocused on the analysis of the "actions" and "resources" put forward by companies to manage their negative "impacts". This clarification would also help prepare companies for the necessary accounting changes in terms of sustainability, while relieving them of the need to speculate on the future.
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