cover image: 2 February 2024 UNEP FI Input to the EFRAG Invitation for Public Feedback on ESRS Implementation Guidance

20.500.12592/k6djphk

2 February 2024 UNEP FI Input to the EFRAG Invitation for Public Feedback on ESRS Implementation Guidance

2 Feb 2024

Finally, in section 5.7 of the Guidelines it is mentioned that if a company reports on any Taxonomy eligible activities it engages in, this can inherently help in the identification of impacts, based on the criteria of substantial contribution of the activity to some of the environmental objectives, and also based on compliance or not with the DNSH for the remaining environmental objectives. [...] Source: UNEP FI adapted from IMP material The two main aspects of the guidance which instill this bias are: on the one hand, the treatment of (affected) stakeholder engagement, and on the other hand, the treatment of materiality assessment criteria and setting thresholds. [...] This makes for somewhat ambiguous reading for the user: are some parts of the guidance more authoritative than others? Are there completely different ways of doing things? ➢ SUGGESTION: Given the disclaimers included at the very front of the document which clearly signal that the material is non-authoritative, the text itself could be ridded of further allusions to this. [...] ➢ SUGGESTION: It would be helpful to introduce a simple visual representation of the process as a whole, including the distinction between the materiality assessment process and the determination of material information, and to include it in the very first part of Section 2. [...] While there will always be entity-specific impacts, the bulk of material impact topics are driven by the nature of the activities / the sector of the undertaking.

Authors

Careen Abb

Pages
8
Published in
Switzerland