Deloitte comment letters (Other)

A key part of due process is constituent feedback. This page provides quick access to Deloitte comment letters on key proposals from various organisations, such as papers from regional and local standard setters, proposals from regulatory bodies, and responses to proposals from other relevant bodies.

Related Publications

Deloitte comment letter on the proposed governance model of the TISFD

31 Jul 2024

Deloitte Touche Tohmatsu Limited (Deloitte) welcomes the opportunity to provide comments on the proposed governance model for the Taskforce on Inequality and Social-related Financial Disclosures (TISFD).

Deloitte comment letter on the proposed scope and mandate of the TISFD

31 Jul 2024

Deloitte Touche Tohmatsu Limited (Deloitte) welcomes the opportunity to provide comments on the proposed scope and mandate of the Taskforce on Inequality and Social-related Financial Disclosures (TISFD).

Deloitte comment letter on GRI Topic Standard Project for Climate Change — 'Climate Change' and 'Energy' exposure drafts

05 Mar 2024

Deloitte Touche Tohmatsu Limited welcomes the opportunity to respond to the 'Climate Change' and 'Energy' exposure drafts (EDs) issued by the Global Reporting Initiative’s (GRI) Global Sustainability Standards Board (GSSB). There is increasing focus by stakeholders on the actions being taken by entities to support commitments made to address climate change. We agree, therefore, that the matters addressed in the EDs should be reflected in the GRI Standards.

Deloitte comment letter on EFRAG draft implementation guidance

05 Feb 2024

We have commented on the EFRAG draft implementation guidance on materiality assessment, value chain and list of ESRS datapoints.

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

10 Jul 2023

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 European Commission 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.

Deloitte comment letter on TNFD Beta Framework

02 Jun 2023

We have commented on the Taskforce on Nature-related Financial Disclosures (TNFD) – Feedback on v0.4 of the TNFD Beta Framework.

Deloitte response to the survey on the need for GHG protocol corporate standards and guidance updates

22 Mar 2023

In our response, we emphasise aspects of the GHGP for which we believe there is a need for greater consistency. In particular, we recommend that that the Corporate Standard should use terminology from widely-adopted financial reporting standards – notably IFRS Accounting Standards and U.S. GAAP, to the extent possible. We believe this is particularly important to promote connectivity of GHG emissions disclosures with financial reporting.

Deloitte comment letter on the GSSB’s draft work programme

17 Feb 2023

We have no direct suggestions on the proposed order of prioritisation for reviewing the existing GRI Standards. However, we consider that, as an overall approach, revisions to the GRI Standards should seek to enhance interoperability with those developed and issued by the International Sustainability Standards Board (ISSB) and other significant sustainability standards-setters. We agree that expanding coverage of climate-related matters is important, nevertheless, we also emphasise the increasing importance of social topics to business.

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

10 Aug 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 European Sustainability Reporting Standards (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.

Deloitte comment letter on SEC proposal on climate-related disclosures for investors

31 May 2022

We have responded to the request for public comment from the Securities and Exchange Commission (SEC) on the proposed rule ’The Enhancement and Standardization of Climate-Related Disclosures for Investors’.

Deloitte response to EFRAG consultation on due process procedures on EU sustainability reporting standard-setting

15 Sep 2021

The Deloitte firms in the European Union have responded to the EFRAG consultation paper 'EFRAG Due Process Procedures on EU Sustainability Reporting Standard-Setting'.

Deloitte comment letter on the proposed CSRD

16 Jul 2021

We support many of the proposals of the CSRD, including the development of EU Sustainability Reporting standards (ESRS) allowing for both international consistency and catering for EU needs and its legislative landscape. However, we note that issues at stake are global, investors and other stakeholders are often global, and many companies operate and source through global value chains. Therefore, similar to the G7 ministers of finance and central bank governors, we support a baseline global reporting standard for sustainability to be developed by the IFRS Foundation, which jurisdictions can further supplement.

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Deloitte comment letters (Other)

Related Publications

Deloitte comment letter on the proposed governance model of the TISFD

Deloitte comment letter on the proposed scope and mandate of the TISFD

Deloitte comment letter on GRI Topic Standard Project for Climate Change — 'Climate Change' and 'Energy' exposure drafts

Deloitte comment letter on EFRAG draft implementation guidance

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

Deloitte comment letter on TNFD Beta Framework

Deloitte response to the survey on the need for GHG protocol corporate standards and guidance updates

Deloitte comment letter on the GSSB’s draft work programme

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

Deloitte comment letter on SEC proposal on climate-related disclosures for investors

Deloitte response to EFRAG consultation on due process procedures on EU sustainability reporting standard-setting

Deloitte comment letter on the proposed CSRD

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Correction list for hyphenation