KPIs for SMEs: DRSC submits comment letter to EFRAG

On 27 May 2026, the DRSC submitted a comment letter on EFRAG’s draft report entitled “Draft Assessment of the Interest in a Voluntary Template for SMEs at ESAP”. EFRAG’s draft report stems from an initiative of the European Commission aimed at strengthening the financing environment for small and medium-sized enterprises (SMEs) as well as for innovative start-ups and fast-growing companies.

In its comment letter, the DRSC generally supports the European Commission’s objective of facilitating access to finance for the companies targeted by the initiative. At the same time, however, the DRSC points out that a voluntary reporting template may not be suitable for achieving this objective. The comment letter explains the reasons for this assessment and also highlights unresolved implementation challenges.

Background:

In July 2025, the European Commission mandated EFRAG to assess the level of interest in a voluntary reporting initiative for SMEs, in particular for innovative and fast-growing companies and start-ups. EFRAG was also tasked with discussing a possible structure for a corresponding reporting template, for example in the form of KPIs.

EFRAG subsequently carried out extensive outreach activities with potential preparers and users of such a reporting template to assess potential interest in a voluntary reporting template. The results were summarized in a draft assessment report to the European Commission published on 3 April 2026 and were subsequently opened for public consultation.