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Artikel

15 Dez 2020

Autor:
Alliance for Corporate Transparency

Reform of the EU Non-Financial Reporting Directive

1. SCOPE. Expand the scope of the EU Non-Financial Reporting Directive so as to cover:

  • All public interest companies, irrespective of their size, including non EU companies which securities are admitted to trading in the EU...
  • All large companies as defined in the Accounting Directive...
  • All small and medium-sized companies whose business activities are linked to significant impacts...
  • Financial market participants...

2. ALIGNMENT WITH THE ANNUAL REPORT

  • Ensure that the non-financial statement is made available together with the annual report

3. DOUBLE-MATERIALITY: Clarify the double-materiality definition and principles based on the following:

  • undertakings should consider which information is relevant from the perspective of their economic, social and environmental dependencies [...] and from the perspective of understanding their impact on people and the environment
  • Materiality from the ‘impact’ perspective means information about severe actual negative impacts and potential negative impacts on people and/or the environment

4. GOVERNANCE AND ACCOUNTABILITY: Integrate reporting requirements covering the issues of governance and accountability for sustainability matters:

  • Introduce a requirement mandating undertakings to describe the board’s oversight of and management’s role in assessing and managing of non-financial risks and opportunities...
  • Introduce a requirement mandating undertakings to report on the integration of the non-financial risks, impacts, opportunities, policies and targets...
  • Provide a mandate to the EU standard setter to develop an appropriate standard for reporting on integration of thematic information...

5. GENERAL REPORTING REQUIREMENTS: For each issue reported on, based on the application of the double materiality principle and the thematic requirements and corresponding EU reporting standards (see Section 6), disclosures should include a description of: ...

  • company business model...
  • Material risks and opportunities facing the company arising from each issue and how these are included into the company’s risk management process...
  • The most significant actual impacts and risks of such impacts on people and the environment, alongside an indication of where in the value chain...
  • The strategy put in place by the company to address the identified impacts, risks and opportunities, including actions taken...
  • Targets or objectives and timelines for achieving them [...] and performance against those targets, including KPIs...
  • Information required by the EU taxonomy...
  • Information outlined in specific reporting requirements and corresponding EU reporting standards...

6. THEMATIC REPORTING REQUIREMENTS: In addition to the information requirements in Section 5 above, undertakings should report the thematic information specified below...

  • Climate...
  • Natural resources, biodiversity and ecosystems...
  • Workforce and human rights matters...
  • Anti-corruption...

7. ASSURANCE

  • Non-financial assurance should be subject to mandatory assurance...

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