Nya EU-krav ”Corporate Sustainability Reporting Directive (CSRD)”, förväntas ytterligare skärpa kraven på Hållbarhetsrapportering i Årsredovisningen. Kravet träder i kraft räkenskapsåret 2023.

Nedan är ett utklipp från EU kommissionen:

”Corporate Sustainability Reporting

EU rules require large companies to publish regular reports on the social and environmental impacts of their activities.

On 21 April 2021, the Commission adopted a proposal for a Corporate Sustainability Reporting Directive (CSRD), which would amend the existing reporting requirements of the NFRD. The proposal

  • extends the scope to all large companies and all companies listed on regulated markets (except listed micro-enterprises)
  • requires the audit (assurance) of reported information
  • introduces more detailed reporting requirements, and a requirement to report according to mandatory EU sustainability reporting standards
  • requires companies to digitally ‘tag’ the reported information, so it is machine readable and feeds into the European single access point envisaged in the capital markets union action plan

Scope: why does the proposed Corporate Sustainability Reporting Directive cover more companies?

The reporting rules introduced by the Non-Financial Reporting Directive apply to so-called “public interest entities”, meaning listed companies, banks, and insurance companies. The rules apply to companies that are large (i.e. they are not SMEs, as defined in the Accounting Directive), and have more than 500 employees. In other words, only about 11.000 companies were covered by the NFRD.

Consultations carried out by the Commission found that many stakeholders are in favour of extending reporting requirements to additional categories of companies. Today’s proposal will extend the scope of these requirements to include all large companies, whether they are listed or not and without the previous 500-employee threshold. This change would mean that all large companies are publicly accountable for their impact on people and the environment. It also responds to demands from investors for sustainability information from such companies.

In addition, the Commission is proposing to extend the scope to include listed SMEs, with the exception of listed micro-enterprises. For reasons of investor protection, it is especially important that investors have access to adequate sustainability information from listed companies. Furthermore, if listed SMEs do not report sustainability information, they may find themselves at risk of exclusion from investment portfolios. This risk will grow as sustainability information becomes ever more important throughout the financial system.

Small and Medium-Sized Enterprises (SMEs): what does the proposal mean for smaller companies? 

The proposal would not put any new reporting requirements on small companies, except for SMEs with securities listed on regulated markets. In addition, to limit the burden on listed SMEs, they will be allowed to report according to standards that are simpler than the standards that will apply for large companies.  The reporting requirements of this proposal would also not apply to SMEs with transferable securities listed on SME growth markets or multilateral trading facilities (MTFs).

That said, many SMEs are facing growing requests for sustainability information – typically from banks that lend them money and large companies that they supply. The transition to a sustainable economy is likely to mean that collecting and sharing sustainability information becomes common business practice for companies of all sizes. Therefore, in parallel to the new rules proposed today for large companies, the Commission is also proposing the development of separate, proportionate standards for SMEs. SMEs listed on regulated markets could use these simpler standards to meet their legal reporting obligations, while non-listed SMEs could choose to use them on a voluntary basis. These standards would be carefully adapted to the capacity of SMEs. They would make it easier for SMEs to report information to banks, large-company clients and other stakeholders. They can help SMEs play a full role in the transition to a sustainable economy. Furthermore, the requirements for listed SMEs would apply only three years after they apply to other companies, given the economic difficulties faced by smaller companies as a result of the COVID-19 pandemic.

Audit: what does the proposal say about the audit of sustainability information?

The proposal would for the first time introduce a general EU-wide audit (assurance) requirement for reported sustainability information. This will help to ensure that reported information is accurate and reliable. It should go a long way towards addressing the concerns of investors and other stakeholders about the reliability of the sustainability information that companies report today.

Although the objective is to have a similar level of assurance for financial and sustainability reporting, a progressive approach is needed. The Commission is proposing to start with a ‘limited’ assurance requirement. This represents a significant advance on the current situation, while not imposing a ‘reasonable’ assurance requirement (a stronger, more demanding level) for the time being. A limited assurance requirement is less costly for companies, and better corresponds to the current capacity and technical ability of the market for audit (assurance) services. Reasonable assurance of sustainability reporting is difficult at this stage in the absence of sustainability assurance standards. The proposal therefore gives the Commission the possibility of adopting such standards. If the Commission does adopt sustainability assurance standards, then the legal requirement would automatically become a requirement for reasonable assurance instead of limited assurance.

The Commission’s proposal allows Member States to open up the market for sustainability assurance services to so-called ‘independent assurance services providers’. This means that Member States could chose to allow firms other than the usual auditors of financial information to assure sustainability information.

Digitalisation: will the proposal make information available in a digital format?

The Commission’s proposal anticipates the increasing digitalisation of sustainability information. This trend holds out the possibility over time of lower reporting costs for companies and radical improvements in how investors and other stakeholders can compare and use reported information. Specifically, the proposal would require companies to prepare their financial statements and their management report in XHTML format in accordance with the ESEF Regulation[1] and to ‘tag’ their reported sustainability information according to a digital categorisation system as and when specified in that Regulation. This digital categorisation system would be developed together with the sustainability reporting standards.

This will mean that sustainability information can easily be incorporated in the European Single Access Point envisaged in the Capital Markets Union Action Plan, for which the Commission will put forward a proposal later this year. Digitalisation of companies’ sustainability reporting is also in line with the Digital Finance Strategy, which aims at enhancing access to data and re-use of data within the financial sector.

Timing and next steps: co-legislators to negotiate

The next step is for the European Parliament, and the Member States in the Council, to negotiate a final legislative text on the basis of the Commission’s proposal.

In parallel, EFRAG will start work on a first set of draft sustainability reporting standards. These draft standards could then be ready for consideration by the Commission once the Parliament and Council have agreed a legislative text. EFRAG aims to have the first set of draft standards ready by mid-2022.

The final timetable will depend on how the Parliament and Council progress in their negotiations. If they reach agreement in the first half of 2022, then the Commission should be able to adopt the first set of reporting standards under the new legislation by the end of 2022. That would mean that companies would apply the standards for the first time to reports published in 2024, covering financial year 2023.”