EFAMA strongly supports the initiative carried out by EFRAG with the publication of the Exposure Drafts on the European Sustainability Reporting Standards (ESRS). The Exposure Drafts provide key elements framing the architecture of reporting requirements and clarifying the content and key concepts of CSRD. The resulting data will be of crucial importance for investors and for achieving the EU objective to transition towards a zero emissions economy by 2050. 

A global alignment of sustainable reporting standards is necessary to guarantee comparability, transparency and reliability of the information provided. At the same time, it will reduce the complexity and reporting burden not only for reporting entities but also for users of sustainability-related information. We, therefore, encourage EFRAG to coordinate closely with the ISSB and the Global Reporting Initiative (GRI) to design a global baseline of sustainability reporting standards and to ensure interoperability of standards.

In addition to these points, we would like to underline some key recommendations which are further explained in our detailed response to the consultation:

• The importance of using the ‘double materiality’ principle 
• Ensuring subjectivity of materiality rebuttals is minimized
• Using a phase-in approach to allow a progressive implementation of the CSR