We welcome the approach EFRAG has taken to this consultation and welcome the engagement with stakeholders through the standard setting process. We welcome this public consultation and the opportunity to respond.
We support the EFRAG’s objective of a rigorous and transparent due process that underpins the standard setting and also agree with the proposed due process procedures that address the principles of transparency, public consultation and impact.
To meet the growing demands of investors, policymakers, and other stakeholders, a reporting system that produces globally consistent, comparable, reliable, and measurable sustainability information is needed. As such, we are supportive of a global approach to sustainability standard- setting and the proposed Corporate Sustainability Reporting Directive (CSRD).
We support the approach that the IFRS Foundation is undertaking. The IFRS Foundation are intending to leverage standards from existing global frameworks. We support the strategic direction of the CSRD, where it remains consistent with the work of the IFRS Foundation. The EU as they look to expand and introduce new sustainability standards should build on the of work by the IFRS Foundation to create and introduce global standards in this space.
Many businesses operate globally within the EU; therefore, standards developed for use in the EU should be aligned to global standards so businesses can successfully implement the standards across all nations they operate in. If EU standards are entirely different compared to globally agreed standards, this could create duplication and unnecessary bureaucracy for those global organisations.
The Statement of Intent to Work Together Towards Comprehensive Corporate Reporting (“Statement of Intent”) issued by the CDP, CDSB, GRI, and the Value Reporting Foundation provides, among other things, a joint vision of how their frameworks and standards could complement financial generally accepted accounting principles (financial GAAP) and serve as a natural starting point for progress towards a more coherent, comprehensive corporate reporting system. It further highlights a joint commitment to drive toward this goal, through an ongoing programme of deeper collaboration between themselves, and a stated willingness to engage closely with other interested stakeholders.
We commend EFRAG’s Task Force for undertaking the statement of cooperation with GRI. We believe this is a first step towards working to a global solution and is in this same spirt as the Statement of Intent. We strongly encourage EFRAG to collaborate with other bodies such as the Value Reporting Foundation and those who have signed the Statement of Intent. We also strongly encourage an EFRAG cooperation arrangement with the IFRS Foundation.