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18 March 2024 — Consultation Response

ESMA’s consultation Draft Guidelines on Enforcement of Sustainability Information

We responded to ESMA’s consultation Draft Guidelines on Enforcement of Sustainability Information (GLESI).

We provide some ideas for ESMA and enforcers to enhance coordination with stakeholders. This include to:

  • clarify the role & focus of enforcers in their sustainability reporting enforcement
  • recognise auditors’ (different) role and foresee regular communications with them
  • recognise the learning curve of all stakeholders and the scarcity of resources
  • ensure coordination measures between examinations of FR and SR
  • escalate enforcers’ findings to TCWG

We also propose the following considerations:

  • clarify materiality concepts
  • link the objectives of GLESI to the sustainability reporting framework
  • strengthen quality reviews
  • draw lessons from EMSA “guidelines of the enforcement of financial information”