"Letter from GRI addressed to President of the European Commission, Executive Vice-President for Prosperity & Industrial Strategy, Commissioner for Economy, Productivity & Implementation & Simplification, and Commissioner for Financial Services & the Savings & Investments Union" 18 February 2025

On behalf of the Global Reporting Initiative (GRI), I am reaching out regarding the European Commission's preparations for the First Omnibus package on sustainability. While we fully understand the drive for a more competitive European economy, we believe CSRD and ESRS as currently set out deliver on this goal, by driving investment toward future-fit business. Double Materiality, aligned with international standards, strengthens Europe's competitiveness by creating a seamless, interoperable reporting system that cost-effectively delivers globally comparable, decision-useful data for investors and other stakeholders.

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We also support the principle of double materiality in the CSRD. EU co-legislators and the European Commission agreed that this principle is essential for effective sustainability reporting, ensuring companies manage financial risks while also addressing their broader impacts on the environment, people, and the economy.

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Disclosure of external impacts better enables investors, policymakers, businesses, and other stakeholders to navigate major risks-like climate change and human rights abuses.

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Dropping Double Materiality would set Europe back to 2014 -- pre-NFRD. At that time, there was no mechanism to hold companies accountable for their impacts

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The EU has been a key driver of high-quality sustainability reporting standards -- maintaining this leadership is crucial for global convergence, a competitive and level playing field, and meaningful realworld impact. We strongly urge the European Commission to ensure that the First Omnibus package on sustainability maintains double materiality and the alignment between ESRS and international sustainability standards. Any dilution would undermine global data comparability, hindering effective capital allocation.