The EACB welcomes EFRAG’s initiative to simplify and refine the first set of sector-agnostic European Sustainability Reporting Standards (ESRS). EACB stresses that the current ESRS framework remains overly complex and insufficiently tailored to the financial sector. In particular, the EACB calls for clearer guidance on the double materiality assessment, a stronger focus on genuinely material impacts, as well as reduced narrative and process-related disclosure requirements. EACB also advocates for a uniform consolidation scope aligned with financial reporting and clearer definitions of “own operations” and value chains to ensure consistency, legal coherence and comparability.
EACB further recommends the streamlining of narrative information, the deletion or conversion of non-critical data points into voluntary guidance, and greater flexibility for financial institutions to disclose actions and targets that reflect their indirect (Scope 3) sustainability impacts. Quantitative disclosures should focus on relevant, decision-useful metrics, while sectoral guidance should be reintroduced to ensure comparability within banking sector. EACB also highlights the need to harmonise the ESRS with existing EU and international frameworks such as the EBA’s Pillar 3, SFDR, Taxonomy and ISSB standards to prevent regulatory overlap. Finally, a clearer and more coherent structure for the standards is needed, ensuring interoperability and a more efficient, user-friendly reporting system that maintains the quality and credibility of sustainability disclosures across Europe.