Deloitte comment letter on the draft delegated regulation with regard to ESRS

Published on: 10 Jul, 2023

We have commented on the draft delegated regulation supplementing the European Accounting Directive as regards sustainability reporting standards released for comment by the European Commission (EC) in June 2022.

We support the objectives of the European Green Deal and policy and regulation that are designed to enable the flow of high-quality, consistent and comparable sustainability information which is essential to support these objectives. We welcome the steps that the EC has already taken to simplify the European Sustainability Reporting Standards (ESRS) requirements by ensuring that all disclosure requirements and data points in topical standards are subject to materiality; making some disclosure requirements voluntary; and improving the understandability of the standards. Our key comments are set out in a cover letter with an appendix some comments, requests for clarification, and suggested edits on the draft ESRS, provided by some of our Deloitte experts. Our comments submitted do not represent an exhaustive set of comments due to the limited amount of time available for review of the draft delegated regulation.

Please click to download our comment letter below.


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