Deloitte comment letter on the draft European Sustainability Reporting Standards (ESRS)

Published on: 10 Aug 2022

We have commented on the draft European Sustainability Reporting Standards (ESRS) developed by the European Financial Reporting Advisory Group (EFRAG) and released for comment in April 2022.

Deloitte supports consistent reporting of high-quality, relevant, reliable and comparable information that will enable investors and other relevant stakeholders to make decisions that support the transition to a green and inclusive economy. The draft ESRS are comprehensive and generally have the potential to result in relevant information, but we have key concerns that they will create issues for the quality of the information provided, the effective implementation and enforceability of the standards, and consequently will not support the ultimate objective.

    We believe that these issues need to be addressed before ESRS are finalised and issued and ask that EFRAG:

    • continues to work closely with the International Sustainability Standards Board (ISSB) to drive convergence and achieve a global baseline of sustainability information, taking advantage of the current window of opportunity to align before the respective standards are finalised;
    • addresses the overall volume of required disclosures in the proposed package of ESRS and ensures they are practical for companies to implement and relevant to users considering costs and benefits, particularly in the first years; and
    • allows for a more reasonable timeline to finalise the standards and adhere to the due process.

    Please click to download the full comment letter below.


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