The EACB has highlighted the following key issues:
• Entity-specific disclosures should be voluntary.
• A two-year phase-in period for the SNCIs and captive insurance undertakings within the scope of the LSME standard should be allowed as this would ease the significant challenges these smaller institutions face in implementing the ambitious new reporting requirements.
• The SNCI-threshold should be at least 500 employees (NFRD threshold).
• Regarding the inclusion of the 'report if you have' disclosures as a 'shall', as the legislator has deliberately chosen to exclude them from the list of explicit content to be covered in LSME, EFRAG cannot include them as a 'shall'. Instead, we propose to include them as a “may”.
• The current lack of a specific definition for SNCI's value chain presents a challenge.
• Scope 3 GHG emissions are particularly difficult to measure and involve disproportionately high costs.