EUU, Alm.del - 2024-25 - Bilag 720: Notat samt høringssvar vedr. forenklede europæiske standarder for virksomheders bæredygtighedsrapportering

Europaudvalget 2024-25
EUU Alm.del Bilag 720
Offentligt

MINISTER FOR INDUSTRY,

BUSINESS AND FINANCIAL

AFFAIRS

Danish Government response to EFRAG public consultation on draft

amended ESRS

The Danish Government finds it necessary to significantly reduce the

burdens of sustainability reporting. Companies should only be required

to provide information that the market demands in relation to green fi-

nancing, and the infrastructure for sustainability reporting must be co-

herent across the value chain and sectors. The Danish Government sees

potential in streamlining and simplifying the standards for sustainability

reporting significantly.

The Danish Government therefore welcomes the proposed amendments

to the ESRS and thanks EFRAG for the work and effort put into the

simplifications. The changes have made a much-needed reduction in

datapoints and simplified and made clearer the principles of the sustain-

ability reporting process. That said, the Danish Government would be

supportive should further feasible reductions in datapoints be identified

and taken into consideration.

The Danish Government wishes to highlight that the double materiality

assessment is crucial for ensuring both relevant reporting and a reduc-

tion in administrative burdens. While the amended ESRS standards

have brought greater clarity to the concept of double materiality, the

process itself has not been simplified or reduced in scope. We are there-

fore concerned that these changes may not achieve a sufficient allevia-

tion of reporting burdens.

It is crucial that reporting focuses on material topics and material infor-

mation to ensure relevant reporting that is useful for decision-making.

Also, sector guidance is especially called for in the market. Therefore,

the Danish Government believes that sector-specific guidance can sup-

port and limit the double materiality assessment in such a way, that the

reporting is focused and useful, especially for the financial sector. In

this way, it is possible both to reduce the burden on reporting compa-

nies, as their double materiality assessment becomes less extensive and

more sector-oriented, and to make the reporting more decision-useful.

At the same time, ensuring a high level of interoperability between dif-

ferent legislative frameworks and international standards that busi-

nesses are met with is important to avoid unnecessary burdens including

double reporting, duplicative work as well as to enhance understanda-

bility.

MINISTRY OF INDUSTRY,

BUSINESS AND FINANCIAL

AFFAIRS

Slotsholmsgade 10-12

DK-1216 Copenhagen K

Denmark

Tlf.

Fax

+45 33 92 33 50

+45 33 12 37 78

CVR-nr. 10092485

EAN nr. 5798000026001

[email protected]

www.em.dk

EUU, Alm.del - 2024-25 - Bilag 720: Notat samt høringssvar vedr. forenklede europæiske standarder for virksomheders bæredygtighedsrapportering

We believe that EFRAG has achieved this to some degree, however, we

find that there are still some areas of concern that we would like to bring

to EFRAG’s attention and request EFRAG to revisit in order to ensure

a common understanding amongst company preparers, auditors, finan-

cial institutions and authorities.

For instance, we have already found different understandings amongst

preparers and auditors regarding what should constitute the scope of re-

porting, including how much entity-specific information to include in

the context of the requirements related to the double materiality assess-

ment and the concept of

“fair presentation”.

For financial sector under-

takings this ambiguity is further exacerbated, since the definition of the

value chain of financial undertakings remains unclarified. To mitigate

this, a clear definition of the value chain of financial undertakings

should be included in the directive, as suggested by EFRAG. Alterna-

tively, if no such definition is included, sector-specific guidance should

include such a definition.

We have also observed a number of differences in interpretation be-

tween auditors and preparers. Although this will, in our view, be par-

tially mitigated through enhanced interoperability, we find it crucial to

eliminate any remaining risks of ambiguity in the standards. EFRAG

can achieve this by ensuring that terminology and concepts in the stand-

ards are sufficiently clarified and that, where significant differences in

terminology or approaches exist, in-depth guidance or clarification is

provided.

Furthermore, we would like to highlight to EFRAG the importance of

ensuring strong interoperability between the ESRS standards and the

voluntary SME standards (VSME), in order to minimize any potential

trickle-down effects on undertakings in the value chain.

Finally, navigating the regulation, which includes the standards, the di-

rective, and potentially Q&As, is very complex and challenging. We

therefore see a strong need for guidance from the Commission, both

regarding the interpretation of the standards themselves and for audi-

tors, in order to ensure shared understanding and reduce any diver-

gences.

If anything is unclear or questions arise, please do not hesitate to reach

out.