EFRAG’s draft IG 2 value chain implementation guidance 

We have responded to EFRAG’s draft IG 2 Value Chain Implementation Guidance. We welcome this guidance as it addresses and clarifies a key concept in the European Sustainability Reporting Standards (ESRS). However, we suggest more guidance and practical examples on determining:

• the value chain boundaries
• operational control, including addressing the different considerations in topical ESRS, determining operational control in various situations and considering the financial sector.

We suggest EFRAG collaborates with the International Sustainability Standards Board (ISSB) and the Global Reporting Initiative (GRI) as all organisations work on providing implementation support on value chain.

We also provide some ideas for EFRAG and the European Commission to consider in the future, which would further help implementation:

• aligning contents with the Q&A platform
• considering future ESRS amendments
• updating the ESRS Basis for Conclusions
• reactivating the European Lab.