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29 July 2022 — Consultation Response

EFRAG PTF-ESRS exposure drafts on European sustainability reporting standards

We have responded to the exposure drafts (EDs) on European sustainability reporting standards (ESRS) issued by EFRAG Project Task Force on ESRS.

Cross-cutting draft standards

Full responses:

  • ESRS 1 General principles ED (see our feedback to questions 1 – 38 in sections 1A, 1B and 1C)
  • ESRS 2 General, strategy, governance and materiality assessment disclosure requirements ED (see our feedback to question 39 in section 1C  and questions 1 – 22 in section 3A)

Environment draft standards

Full response:

  • ESRS E1 Climate change ED (see our feedback to question 40 in section 1C and questions 23 – 39 in section 3B)

High level feedback:

  • ESRS E2 Pollution ED (see our feedback to question 41 in section 1C)
  • ESRS E3 Water and marine resources ED (see our feedback to question 42 in section 1C)
  • ESRS E4 Biodiversity and ecosystems ED (see our feedback to question 43 in section 1C)
  • ESRS E5 Resource use and circular economy ED (see our feedback to question 44 in section 1C)

Social draft standards

Full response:

  • ESRS S1 Own workforce ED (see our feedback to question 45 in section 1C and questions 73 – 98 in section 3C)

High level feedback:

  • ESRS S2 Workers in the value chain ED (see our feedback to question 46 in section 1C)
  • ESRS S3 Affected communities ED (see our feedback to question 47 in section 1C)
  • ESRS S4 Consumers and end-users ED (see our feedback to question 48 in section 1C)

Governance draft standards

Full responses:

  • ESRS G1 Governance, risk management and internal control ED (see our feedback to question 49 in section 1C and questions 117 – 126 in section 3D)
  • ESRS G2 Business conduct ED (see our feedback to question 50 in section 1C and questions 127 – 138 in section 3D)

We have also written a letter to Commissioner McGuinness on the ESRS EDs available here.