On June 2, the Society and the National Association of Manufacturers (NAM) submitted this joint position paper in response to the European Commission’s consultation on revisions to the European Sustainability Reporting Standards (ESRS).
The position paper focuses on targeted amendments relating to the structure and presentation of information within the sustainability statement, including incorporation by reference and greater flexibility regarding cross-referencing and report organization. The paper argues that greater presentation flexibility would improve operational efficiency and usability for multinational companies subject to the CSRD and other sustainability reporting regimes, while reducing unnecessary duplication, compliance burdens, and the risk of incomplete or inconsistent reporting.
Among other points, the paper recommends:
• Expanding the categories of disclosures that may be incorporated by reference under ESRS 1;
• Providing greater flexibility regarding the organization and structuring of the sustainability statement; and
• Allowing reporting entities to leverage substantively comparable disclosures prepared under other mandatory or widely used sustainability reporting frameworks, subject to existing ESRS safeguards relating to assurance, language, readability, and digital tagging.
The paper also highlights practical challenges facing multinational groups and third-country parent undertakings under the current ESRS presentation requirements, particularly where sustainability information has already been prepared under other reporting frameworks but must be reorganized or reproduced solely to conform to prescribed ESRS presentation formats. The submission is intended to support more effective implementation of the CSRD while improving the usability and consistency of sustainability disclosures across reporting frameworks and jurisdictions.
The Society greatly appreciates the assistance of our members with Kirkland & Ellis in developing the position paper.
Our prior EU sustainability disclosure comment letters, consultation responses, and position papers are here.