21. July 2026

DRSC publishes comment letter on EFRAG’s Discussion Paper on Connectivity

On 15 July 2026, the DRSC published its comment letter on EFRAG’s Discussion Paper “Connectivity of Financial and Sustainability Reporting”. In its response, the DRSC welcomes EFRAG’s work on connectivity as an important step towards integrated reporting.

The DRSC particularly acknowledges EFRAG’s contribution to advancing the discussion on the understanding of connectivity. At the same time, it emphasizes that this discussion should take place within the existing regulatory framework, as regulatory developments based on the considerations in the discussion paper are the responsibility of the relevant standard-setters.

In the DRSC’s view, connectivity should be reflected not only in reporting but also at the transaction level and within corporate structures. Connectivity can be achieved by better linking existing information across various reports. Additional disclosure requirements should first be discussed from a conceptual perspective and should include, for example, other long-term developments in addition to sustainability aspects. The DRSC also recommends a more consistent use of concepts and definitions. Drawing on examples from the Discussion Paper and its discussion of Anticipated Financial Effects (AFE), the comment letter identifies areas where further conceptual and technical clarification is needed. On AFE reporting the DRSC recently conducted a study based on 100 company reports.