PensionsEurope welcomes the opportunity to contribute to the EFRAG on its revised European Sustainability Reporting Standards (ESRS) Exposure Drafts (ED). We welcome the overall simplification of the ESRS drafts, improved clarity, and greater interoperability with IFRS standards, which will help reduce duplication and enhance usability for both preparers and investors.
We particularly support clearer guidance on double materiality, better structuring of connected information, and the streamlining of SFDR-related datapoints, as long as all investor-relevant indicators remain fully covered. However, we remain concerned that some simplifications risk undermining transparency and comparability, especially regarding Policies, Actions and Targets (PAT), the treatment of anticipated financial effects, and reliefs for data quality or undue cost and effort. We stress that safeguards and clear disclosure obligations are needed to ensure robust and decision-useful information, particularly for pension funds relying on high-quality sustainability data. Overall, while the revised ESRS represent progress, we urge further adjustments to maintain accountability, comparability, and alignment with investors’ needs.
For more details see our answer below.
