Today, the ASCG submitted the core messages of its Administrative Board as well as the detailed expert opinion of its Joint Committee on the European Commission’s CSRD proposal to the German Federal Ministry of Justice and Consumer Protection. The main content of the comments (comment letter only in German) covers:
- an emphasis on the need for international standards and their more concrete integration into the European reporting framework;
- the demand for a more specific definition of the materiality principle and a stronger emphasis on proportionality and practicability of reporting obligations;
- at least a temporary rentention of the option to publish sustainability information outside the management report;
- the specific challenges of the requirement to provide sustainability information in a specific electronic format;
- the ambitious timetable of the European Commission and the resulting need for prioritisation and – as far as possible – adjustments to the timetable.
The content and positioning with regard to the CSRD proposal will also be subject of the event “15. Berliner Bilanz Forum”, which the BDI (The Voice of German Industry) is organising in cooperation with the ASCG on 15 June 2021. .