ESRS exposure drafts (April 2022)
About the Draft European Sustainability Reporting Standards
The European Commission’s proposal for a Corporate Sustainability Reporting Directive (CSRD) envisages the adoption of EU Sustainability Reporting Standards (ESRS).
In this context, EFRAG was requested in a letter from Commissioner McGuinness to provide Technical Advice to the European Commission in the form of fully prepared draft standards and/or draft amendments to Sustainability Reporting Standards.
The proposal for a CSRD requires that EFRAG’s Technical Advice is prepared with ‘proper due process, public oversight and transparency, and with the expertise of relevant stakeholders, and it is accompanied by cost-benefit analyses that include analyses of the impacts of the Technical Advice on sustainability matters’, contributing to the delegated acts through which the ESRS will be adopted in the EU.
In order to meet the ambitious deadlines for submitting the first set of draft ESRS to the European Commission by November 2022 and to benefit from the longest public consultation period possible, it was critical that the public consultation on the Exposure Drafts (EDs) of the first set of ESRS be launched as soon as possible. In this context, the EFRAG SRB decided to launch the public consultation on the basis of the EDs prepared under the sole responsibility of the PTF-ESRS.
Following the EFRAG's Due Process Procedures on EU Sustainability Reporting Standard-Stetting, which stipulate the requirements in respect of its role as technical advisor to the European Commission in the preparation of draft ESRS, the EFRAG SRB used the exposure drafts as prepared by the PTF-ESRS for public consultation.
These EDs correspond to the requirements under the CSRD proposal and cover the full range of sustainability matters: environment, social, governance and cross-cutting standards.
The intention was for EFRAG SRB and the EFRAG SR TEG to consider the EDs in parallel with the public consultation and following the handover by the PTF-ESRS. Together with the input and results from the public consultation, the EFRAG SRB supported by the EFRAG SR TEG then agreed the final first set of draft ESRS to be submitted to the European Commission.
Public consultation and responses received
On 29 April 2022, EFRAG launched a public consultation on the Draft ESRS EDs, with a deadline of 8 August 2022. A broad spectrum of stakeholders responded to the public consultation, mostly through the two-part online survey.
The EFRAG Sustainability Reporting Board (EFRAG SRB) and EFRAG Sustainability Reporting Technical Expert Group (EFRAG SR TEG) considered all comments received, as required by the EFRAG Due Process Procedures.
All responses received in the public consultation are available through the links below (please note it may take some time for contributions to display):
- Survey 1 - Overall ESRS exposure drafts relevance (Architecture, Implementation of CSRD principles, Exposure Draft content, Implementation prioritisation)
- Survey 2 - Adequacy of disclosure requirements (cross-cutting and topical standards)
It should be noted that the above data is as submitted by respondents to the consultation and may contain a limited number of duplicate or blank submissions.
EFRAG also received comment letters that did not address the specific aspects covered by the questions listed in the online survey:
- Comment letters uploaded to online survey
- Additional comment letters submitted to EFRAG
- Comments received after 8 August 2022 are available here.
Quantitative and qualitive analysis of the input from the public consultation
EFRAG commissioned a quantitative and qualitative study of the feedback received from the public consultation of ESRS EDs from Ramboll Management Consulting. The following reports were received:
- The qualitative analysis of the free-text input received by using the Qualitative Data Analysis software package NVivo (see for more details the Methodological Note in Section 2 of the Reports).
- For each ED a quantitative (statistical) analysis of the closed-question responses. The statistical data extracted has been reformatted by the EFRAG Secretariat for greater clarity.
The terms of use of these two reports may be found in the disclaimer sections of the respective reports.
- To see the Contractor’s Qualitative Analyse Reports, please click here: Ramboll - Reports on Qualitative Analysis of Surveys
- To see the Statistical Analysis, please click here: ESRS Public Consultation - Statistics
Outreach events
During the public consultation period, EFRAG organised 16 outreach events in several EU countries to engage closely with stakeholders and get feedback on the Draft ESRS EDs. These outreach events attracted significant interest with close to 5000 registrations overall.
tables
Joint Educational sessions EFRAG SRB and EFRAG SR TEG
Access the Draft ESRS Exposure Drafts & Set of Basis for conclusions
The Draft ESRS of the PTF-ESRS and its appendices are published as a series of six documents: (i) the complete first set of draft standards, the appendices and cover note and (ii) four separate documents dividing the ESRS by topics including the drafts standards.
Cross-cutting standards
