The EACB welcomes the European Commission's efforts to revise the ESRS under the CSRD, acknowledging that the revised draft brings several meaningful improvements, including clearer drafting, simplifications regarding data collection and useful transitional reliefs. However, further targeted adjustments remain necessary to ensure that the revised ESRS effectively deliver simplification in practice, strengthen legal certainty and remain proportionate for reporting companies.
A key concern in the EACB comments is the consistent and operational application of the materiality principle. Sustainability reporting should focus on decision-useful information. The revised ESRS should provide clearer safeguards against checklist-style reporting and not require undertakings to justify every omitted datapoint or conduct exhaustive searches beyond usual information sources.
Concepts of proportionality, "undue cost or effort" and "reasonable and supportable information" must become genuinely operational, with clear criteria for when data is not reasonably obtainable and the ability to rely on prior period assessments unless material circumstances have changed.
From a banking perspective, the EACB seeks clarifications on the treatment of financed emissions, climate targets, value chain reporting, and the interaction with prudential supervisory expectations. The financial control approach should generally be prioritised for GHG emissions to ensure consistency with financial reporting boundaries; Scope 3 targets should permit intensity metrics and sectoral pathways rather than misleading absolute figures; value chain reporting should be limited to information obtainable from direct counterparties. It is crucial that voluntary standards like VSME do not become de facto mandatory.
Finally, the EACB stresses that simplification efforts will only be fully effective if sustainability reporting requirements, supervisory expectations and underlying data availability are better aligned. To this end, we call for swift finalisation of the revised ESRS backed by practical implementation support, including a comprehensive ESRS data field list.