EFAA Response to the EFRAG Public Consultation on the First Set of Draft ESRS

EFAA being the champion and unique voice of small- and medium-sized accountancy practices, we responded to the public consultation by focusing on the impact and implications for SMEs and SMPs. Therefore, EFAA responded to most of Section 1, all of Section 2 and none of Section 3. The accompanying letter sent to Commissioner McGuinness highlights our key arguments on:
– Sustainability;
– Due process;
– Capacity of SMEs and SMPs;
– Proportionality;
– Materiality;
– Reporting Boundary and Value Chain;
– Prioritization and Phasing-In
– Interoperability with Global Standards;
– Sustainability Standards for SMEs

Our replies to the consultation are available here