EFAA for SMEs appreciates the opportunity to comment on the European Commission (EC) Consultation on the Draft ESRS Delegated Act.
While the four week consultation period has presented us significant challenges in compiling a robust response, a challenge exacerbated by the extent of the many changes the EC has made to the draft standards it received from EFRAG, we fully recognize the EC has good justification for this. We strongly support the timely and robust development and implementation of the ESRS. And we strongly support the ECs efforts to simplify this first set of ESRS and EFRAGs timely development of implementation guidance. We believe the EC has struck a reasonable balance between ambition and pragmatism. Notwithstanding our support, we continue to have concerns about the indirect impact of the ESRS on non-listed SMEs. This impact is primarily the consequence of applying impact materiality through value chain reporting. We believe this will impede the Commissions desire to reduce the reporting burden on companies, especially SMEs, by 25%. Accordingly, we question whether there is a need for more support for non-listed SMEs that are in the value chain of in scope companies. We elaborate on these concerns and the potential additional action and support to address them below. We recognize that non-listed SMEs are instrumental to the timely sustainable transition of the EU economy and but that they need help and time if they are to play their full part in this transition.
Here is our feedback in full.
