In this series, we explore several under-the-radar EU Corporate Sustainability Reporting Directive resources published over the summer. U.S.-based multinationals will find these resources helpful as they prepare for CSRD compliance.
The last post in the series discussed the European Securities and Markets Authority's July 2024 Public Statement on the first application of the European Sustainability Reporting Standards adopted pursuant to the CSRD. For that post, see here.
European Financial Reporting Advisory Group (EFRAG) Study
In this post, we discuss EFRAG's study entitled Implementation of ESRS: Initial Observed Practices from Selected Companies. That study, also published in July, provides insights on some preliminary practices and challenges in implementing the ESRS as of Q2 2024. The study was developed for use by large listed and unlisted undertakings that are subject to the CSRD.
For the uninitiated, EFRAG is the technical adviser to the European Commission that developed the draft ESRS issued under the CSRD. Its mission is to serve the European public interest in both financial and sustainability reporting by developing and promoting European views in the field of corporate reporting.
The EFRAG study illustrates preliminary observed practices and challenges related to four focus areas of ESRS implementation. The study includes inputs from 28 large European-headquartered undertakings across eight different industries, split evenly between financial institutions (FIs) and non-financial institutions (non-FI's).
Within the FI component, banks, insurers and asset managers were consulted. In non-FI, companies in healthcare, technology, chemicals, road transport, textiles and utilities participated. The included undertakings were chosen due to their higher level of reporting maturity and the greater resources at their disposal. The study findings are consistent with what we have been seeing in our U.S. client base across a wide range of industries.
Although the study is not authoritative guidance and included a limited sample set of voluntary participants, it provides useful experience from larger companies that began their CSRD journey early. For authoritative guidance, see EFRAG's Materiality Assessment Implementation Guidance (IG 1) discussed in this Ropes & Gray post and its Value Chain Implementation Guidance (IG 2) discussed in this post.
Double Materiality Assessment (DMA)
- Overall, study participants are taking an objective evidence-based approach to their DMA, rather than the judgment-based approach previously used by many companies to assess materiality of sustainability topics under the Global Reporting Initiative and Sustainability Accounting Standards Board standards. Approximately 70% of the undertakings already have started to deploy an objective evidence-based approach to their DMA.
- The evidence-based approach is relying primarily on internal and third-party data that is complemented, mainly where data is not available, by the judgment of internal experts and stakeholders. A range of options are being considered for engagements, including in-depth interviews (70%), workshops (45%), surveys in combination with interviews/workshops (approximately 70%) and surveys alone (approximately 5%). Over 65% of the study undertakings are using two or more channels to reach and collect stakeholder insights.
- While financial materiality quantification can leverage analysis/thresholds that have been used for risk management purposes (approximately 80% of the undertakings take this approach), impact materiality is more likely to be affected by limited data and sector-specific methodologies/thresholds.
- Most participating undertakings recognize the value of a thorough, objective, evidence-based DMA (versus a mostly qualitative/judgmental DMA) as a strategic exercise for setting ESG managerial priorities. Approximately 85% of the undertakings intend to integrate ESG reporting and the results of the DMA into business strategy and decision-making. However, a few participating undertakings consider the DMA to be a compliance exercise.
Datapoints
- Many undertakings have not yet integrated DMA outcomes with their gap analysis of datapoints to be reported, possibly leading to the inclusion in the gap analysis of more datapoints than the ESRS require. Approximately 80% of the undertakings mentioned the complexity of retrieving data, with similar obstacles found across the E, S and G pillars.
- Approximately 95% of the undertakings are using EFRAG Implementation Guidance 3 to run their gap analysis. IG 3: List of ESRS Datapoints presents the ESRS requirements in Excel format. Approximately 20% of the participating undertakings also are using IG 3 as a preliminary basis for anticipating upcoming digital tagging.
- Given the complexities encountered and the efforts required to retrieve and manage data, most undertakings are focusing their reporting efforts. Approximately 75% of the undertakings are utilizing applicable phase-ins. Phase-ins are further discussed in this Ropes & Gray post. Approximately 40% are assessing information materiality at a datapoint level (the study notes that this concept does not yet seem to be well understood by the participants). Approximately 10% plan full disclosure of datapoints related to material topics, choosing to report voluntary datapoints. Approximately 10% are opting to disclose voluntary datapoints that they already report. (Note that the percentages do not add up to 100% since not all options are mutually exclusive.)
Value Chain
- The value chain assessment is the least developed area for the undertakings that participated in the study.
- Several undertakings are engaging in simplified aggregated mapping of the value chain (i.e., only broken out into the categories of upstream, downstream and own operations). Approximately 45% of the undertakings have adopted a more granular mapping of their value chain that goes beyond high-level upstream, downstream and own operations only. However, approximately 90% of the undertakings are still working to refine their value chain mapping, looking for the right balance of granularity.
- Several undertakings are utilizing transitional value chain reporting provisions, with possible increased efforts to go beyond tier 1 for the next reporting cycle. However, several are already going beyond tier 1, especially non-financial institutions.
ESG Reporting Organizational Approaches
- The study notes that CSRD reporting is triggering a renewed organizational approach to ESG reporting, with the ownership model for the ESG reporting process being discussed by most undertakings. There are different organizational patterns within the undertakings, with structures differing on a case-by-case basis. Currently, approximately 65% allocate ownership to a single function (e.g., the chief sustainability officer or chief financial officer), while the remainder have a co-leadership approach (e.g., the CFO in charge of reporting and the CSO in charge of the DMA).Thirty percent of undertakings expect changes in their organizational model in the near- or medium-term.
- CSRD reporting has enhanced cross-departmental collaboration. Typically, five or more departments are regularly engaged in CSRD implementation. Beyond the sustainability and finance departments, risk management, human resources and auditing or internal control are the most frequently involved. Departments such as procurement, communications and strategy also are commonly engaged, reflecting the interdisciplinary nature of effective ESG reporting.
- The undertakings expressed consensus that CSRD reporting has highlighted the need for standardizing ESG reporting processes, including data quality controls (akin to financial reporting), in particular in preparation for assurance.
- There also was consensus that CSRD reporting requires additional capabilities and resources, such as headcount, knowledge, data and technology. Approximately 90% of the undertakings have started improving data quality controls, similar to those used for financial reporting. Approximately 85% of the undertakings acknowledge the need for IT transformation.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.