Deloitte comment letter on the BIS consultation on the EU Non-Financial Reporting Directive

Published on: 21 Apr, 2016

We have published our comment letter on the Department for Business, Innovation and Skills (BIS) consultation on the UK implementation of the EU Non-Financial Reporting (NFR) Directive. 

The NFR Directive was approved by the council of the European Union on 29 September 2014. The aim of the NFR Directive is to improve the transparency of certain EU companies as regards non-financial and diversity information. In February 2016 BIS issued a consultation on the UK implementation of the EU NFR Directive.

Overall, we believe that substantial further thought needs to be given as to how the NFR Directive should be implemented. Our key comments are:

  • we do not believe that either of the two implementation options that have been put forward provide an acceptable outcome and we have proposed a third option which we believe is simpler and enacts the NFR Directive effectively without undue burden;
  • the way in which the UK implements the gender diversity requirements of the Directive requires careful thought in terms of how those requirements are implemented, where information should be presented, and the scope of entities to which it applies or should apply;
  • the option to present information as required by the NFR Directive, and other information, in a separate report needs to be considered carefully; and
  • we do not believe that verification of the non-financial information by an independent assurance provider should be made mandatory.

Further comments and full responses to the questions raised in the consultation paper are contained within the full comment letter which can be downloaded below.


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