| Organisation name |
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| Country of origin |
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| 2. Type of respondent |
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| 3. Size |
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| 4. User/Preparer perspective |
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| 5. Subject to CSRD Separate non-financial corps subject to CSRD from those not subject to CSRD? |
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| Q1: in your opinion, to what extent do the structure and articulation of cross-cutting and topical standards adequately support the coverage of CSRD topics and reporting areas? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q2: in your opinion, to what extent is the TCFD framework of reporting areas (governance, strategy, risk management and metrics/targets) compatible with the structure of the ESRS? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q3: in your opinion, to what extent does the approach taken to structure the reporting areas promote interoperability between the ESRS and the IFRS Sustainability Exposure Drafts? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q4: in your opinion, have these European legislation and initiatives been considered properly? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q5: are there any other European policies and legislation you would suggest should be considered more fully? |
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| Q6: in your opinion, to what extent does the proposed coverage of set 1 adequately address CSRD sustainability topics? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have. |
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| Q7: in your opinion, to what extent does the proposed coverage of set 1 (see Appendix I) adequately address SFDR reporting obligations? |
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| If you think this coverage and its implementation could be improved in any way, please specify how and to what specific SFDR indicator your comment relates |
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| Q8: Do you agree with the proposed three options? |
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| Q9: would you recommend any other option(s)? If so, please describe the proposed alternative option(s) |
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| Q10: in your opinion, to what extent do you believe that connectivity between the sustainability reporting and other parts of the management report has been appropriately addressed? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q11: in your opinion, to what extent does the incorporation of information in the Sustainability section by reference to other parts of the management report support cohesiveness throughout corporate reporting? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q12: in your opinion, to what extent do the requirements and provisions on how to include monetary amounts and other financial statement-related quantitative data into sustainability reporting support connectivity with the financial statements? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q13: to what extent do you think that the principle of relevance of sustainability information is adequately defined and prescribed? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q14: to what extent do you think that the principle of faithful representation of sustainability information is adequately defined and prescribed? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q15: to what extent do you think that the principle of comparability of sustainability information is adequately defined and prescribed? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q16: to what extent do you think that the principle of verifiability of sustainability information is adequately defined and prescribed? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q17: to what extent do you think that the principle of understandability of sustainability information is adequately defined and prescribed? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q18: in your opinion, to what extent does the definition of double materiality (as per ESRS 1 paragraph 46) foster the identification of sustainability information that would meet the needs of all stakeholders? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q19: to what extent do you think that the proposed implementation of double materiality (as per ESRS 2-IRO 1, paragraph 74b(iii) and AG 61) is practically feasible? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q20: in your opinion, to what extent is the definition of impact materiality (as per ESRS 1 paragraph 49) aligned with that of international standards? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q21: to what extent do your think that the determination and implementation of impact materiality (as proposed by ESRS 1 paragraph 51) is practically feasible? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q22: in your opinion, to what extent is the definition of financial materiality (as per ESRS 1 paragraph 53) aligned with that of international standards? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q23: to what extent do you think that the determination and implementation of financial materiality (as proposed by ESRS 1 paragraphs 54 to 56) is practically feasible? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q24: to what extent do you think that the (materiality) rebuttable presumption and its proposed implementation will support relevant, accurate and efficient documentation of the results of the materiality assessment? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q25: what would you say are the advantages of the (materiality) rebuttable presumption and its proposed implementation? |
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| Q26: what would you say are the disadvantages of the (materiality) rebuttable presumption and its proposed implementation? |
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| Q27: how would you suggest it can be improved? |
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| Q28: in your opinion, to what extent would approximation of information on the value chain that cannot (practically) be collected contribute to the reporting of understandable, relevant, verifiable, comparable, and faithfully represented sustainability information? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q29: what other alternative to approximation would you recommend in cases where collecting information is impracticable? |
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| Q30: in your opinion, to what extent will the choice of disaggregation level by the undertaking as per ESRS 1 paragraphs 72 to 77 contribute to the reporting of understandable, relevant, verifiable, comparable and faithfully represented sustainability information? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q31: do you think it is relevant to define short-, medium- and long-term horizon for sustainability reporting purposes? |
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| Please explain why |
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| Q32: if yes, do you agree with the proposed time horizons? |
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| Please explain why |
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| Q33: if you disagree with the proposed time horizons, what other suggestion would you make? And why? |
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| Q34: in your opinion, to what extent will DP 1-1 contribute to the reporting of understandable, relevant, verifiable, comparable and faithfully represented information on sustainability related policies? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q35: in your opinion, to what extent will DP 1-2 contribute to the reporting of understandable, relevant, verifiable, comparable, and faithfully represented information on sustainability-related targets and their monitoring? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q36: in your opinion, to what extent will DP 1-3 contribute to the reporting of understandable, relevant, verifiable, comparable, and faithfully represented information on sustainability-related action plans and allocated resources? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q37: is anything important missing in the aspects covered by the bases for preparation? |
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| If yes, please indicate which one(s). Please share any comment you might have on the aspects already covered (make sure to indicate which one you are referring to) |
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| Q38: in your opinion, to what extent can ESRS 1 – General principles foster alignment with international sustainability reporting standards (in particular IFRS Sustainability Reporting S1 Exposure draft)? |
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| Please explain your reservations or your suggestions for improvement or any other comment you might have |
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| Q39: Please, rate to what extent do you think ESRS 2 – General, strategy, governance and materiality assessment |
| A. Covers sustainability information required by articles 19a and 19b of the CSRD proposal (see Appendix II for CSRD detailed requirements) |
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| B. Supports the production of relevant information about the sustainability matter covered |
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| C. Fosters comparability across sectors |
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| D. Covers information necessary for a faithful representation from an impact perspective |
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| E. Covers information necessary for a faithful representation from a financial perspective |
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| F. Prescribes information that can be verified / assured |
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| G. Meets the other objectives of the CSRD in term of quality of information |
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| H. Reaches a reasonable cost / benefit balance |
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| I. Is sufficiently consistent with relevant EU policies and other EU legislation |
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| J. Is as aligned as possible to international sustainability standards given the CSRD requirements |
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| Please share any comments and suggestions for improvement you might have relating to the above questions, referring explicitly to the part of the question you are providing comment |
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| Q40: Please, rate to what extent do you think ESRS E1 – Climate change |
| A. Covers sustainability information required by articles 19a and 19b of the CSRD proposal (see Appendix II for CSRD detailed requirements) |
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| B. Supports the production of relevant information about the sustainability matter covered |
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| C. Fosters comparability across sectors |
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| D. Covers information necessary for a faithful representation from an impact perspective |
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| E. Covers information necessary for a faithful representation from a financial perspective |
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| F. Prescribes information that can be verified / assured |
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| G. Meets the other objectives of the CSRD in term of quality of information |
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| H. Reaches a reasonable cost / benefit balance |
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| I. Is sufficiently consistent with relevant EU policies and other EU legislation |
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| J. Is as aligned as possible to international sustainability standards given the CSRD requirements |
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| Please share any comments and suggestions for improvement you might have relating to the above questions, referring explicitly to the part of the question you are providing comment |
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| Q41: Please, rate to what extent do you think ESRS E2 - Pollution |
| A. Covers sustainability information required by articles 19a and 19b of the CSRD proposal (see Appendix II for CSRD detailed requirements) |
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| B. Supports the production of relevant information about the sustainability matter covered |
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| C. Fosters comparability across sectors |
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| D. Covers information necessary for a faithful representation from an impact perspective |
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| E. Covers information necessary for a faithful representation from a financial perspective |
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| F. Prescribes information that can be verified / assured |
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| G. Meets the other objectives of the CSRD in term of quality of information |
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| H. Reaches a reasonable cost / benefit balance |
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| I. Is sufficiently consistent with relevant EU policies and other EU legislation |
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| J. Is as aligned as possible to international sustainability standards given the CSRD requirements |
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| Please share any comments and suggestions for improvement you might have relating to the above questions, referring explicitly to the part of the question you are providing comment |
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| Q42: Please, rate to what extent do you think ESRS E3 – Water and marine resources |
| A. Covers sustainability information required by articles 19a and 19b of the CSRD proposal (see Appendix II for CSRD detailed requirements) |
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| B. Supports the production of relevant information about the sustainability matter covered |
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| C. Fosters comparability across sectors |
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| D. Covers information necessary for a faithful representation from an impact perspective |
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| E. Covers information necessary for a faithful representation from a financial perspective |
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| F. Prescribes information that can be verified / assured |
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| G. Meets the other objectives of the CSRD in term of quality of information |
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| H. Reaches a reasonable cost / benefit balance |
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| I. Is sufficiently consistent with relevant EU policies and other EU legislation |
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| J. Is as aligned as possible to international sustainability standards given the CSRD requirements |
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| Please share any comments and suggestions for improvement you might have relating to the above questions, referring explicitly to the part of the question you are providing comment |
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| Q43: Please, rate to what extent do you think ESRS E4 – Biodiversity and ecosystems |
| A. Covers sustainability information required by articles 19a and 19b of the CSRD proposal (see Appendix II for CSRD detailed requirements) |
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| B. Supports the production of relevant information about the sustainability matter covered |
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| C. Fosters comparability across sectors |
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| D. Covers information necessary for a faithful representation from an impact perspective |
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| E. Covers information necessary for a faithful representation from a financial perspective |
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| F. Prescribes information that can be verified / assured |
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| G. Meets the other objectives of the CSRD in term of quality of information |
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| H. Reaches a reasonable cost / benefit balance |
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| I. Is sufficiently consistent with relevant EU policies and other EU legislation |
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| J. Is as aligned as possible to international sustainability standards given the CSRD requirements |
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| Please share any comments and suggestions for improvement you might have relating to the above questions, referring explicitly to the part of the question you are providing comment |
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| Q44: Please, rate to what extent do you think ESRS E5 – Resource use and circular economy |
| A. Covers sustainability information required by articles 19a and 19b of the CSRD proposal (see Appendix II for CSRD detailed requirements) |
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| B. Supports the production of relevant information about the sustainability matter covered |
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| C. Fosters comparability across sectors |
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| D. Covers information necessary for a faithful representation from an impact perspective |
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| E. Covers information necessary for a faithful representation from a financial perspective |
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| F. Prescribes information that can be verified / assured |
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| G. Meets the other objectives of the CSRD in term of quality of information |
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| H. Reaches a reasonable cost / benefit balance |
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| I. Is sufficiently consistent with relevant EU policies and other EU legislation |
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| J. Is as aligned as possible to international sustainability standards given the CSRD requirements |
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| Please share any comments and suggestions for improvement you might have relating to the above questions, referring explicitly to the part of the question you are providing comment |
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| Q45: Please, rate to what extent do you think ESRS S1 – Own workforce |
| A. Covers sustainability information required by articles 19a and 19b of the CSRD proposal (see Appendix II for CSRD detailed requirements) |
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| B. Supports the production of relevant information about the sustainability matter covered |
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| C. Fosters comparability across sectors |
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| D. Covers information necessary for a faithful representation from an impact perspective |
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| E. Covers information necessary for a faithful representation from a financial perspective |
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| F. Prescribes information that can be verified / assured |
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| G. Meets the other objectives of the CSRD in term of quality of information |
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| H. Reaches a reasonable cost / benefit balance |
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| I. Is sufficiently consistent with relevant EU policies and other EU legislation |
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| J. Is as aligned as possible to international sustainability standards given the CSRD requirements |
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| Please share any comments and suggestions for improvement you might have relating to the above questions, referring explicitly to the part of the question you are providing comment |
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| Q46: Please, rate to what extent do you think ESRS S2 – Workers in the value chain |
| A. Covers sustainability information required by articles 19a and 19b of the CSRD proposal (see Appendix II for CSRD detailed requirements) |
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| B. Supports the production of relevant information about the sustainability matter covered |
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| C. Fosters comparability across sectors |
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| D. Covers information necessary for a faithful representation from an impact perspective |
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| E. Covers information necessary for a faithful representation from a financial perspective |
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| F. Prescribes information that can be verified / assured |
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| G. Meets the other objectives of the CSRD in term of quality of information |
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| H. Reaches a reasonable cost / benefit balance |
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| I. Is sufficiently consistent with relevant EU policies and other EU legislation |
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| J. Is as aligned as possible to international sustainability standards given the CSRD requirements |
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| Please share any comments and suggestions for improvement you might have relating to the above questions, referring explicitly to the part of the question you are providing comment |
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| Q47: Please, rate to what extent do you think ESRS S3 – Affected communities |
| A. Covers sustainability information required by articles 19a and 19b of the CSRD proposal (see Appendix II for CSRD detailed requirements) |
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| B. Supports the production of relevant information about the sustainability matter covered |
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| C. Fosters comparability across sectors |
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| D. Covers information necessary for a faithful representation from an impact perspective |
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| E. Covers information necessary for a faithful representation from a financial perspective |
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| F. Prescribes information that can be verified / assured |
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| G. Meets the other objectives of the CSRD in term of quality of information |
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| H. Reaches a reasonable cost / benefit balance |
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| I. Is sufficiently consistent with relevant EU policies and other EU legislation |
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| J. Is as aligned as possible to international sustainability standards given the CSRD requirements |
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| Please share any comments and suggestions for improvement you might have relating to the above questions, referring explicitly to the part of the question you are providing comment |
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| Q48: Please, rate to what extent do you think ESRS S4 – Consumers and end-users |
| A. Covers sustainability information required by articles 19a and 19b of the CSRD proposal (see Appendix II for CSRD detailed requirements) |
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| B. Supports the production of relevant information about the sustainability matter covered |
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| C. Fosters comparability across sectors |
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| D. Covers information necessary for a faithful representation from an impact perspective |
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| E. Covers information necessary for a faithful representation from a financial perspective |
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| F. Prescribes information that can be verified / assured |
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| G. Meets the other objectives of the CSRD in term of quality of information |
|
| H. Reaches a reasonable cost / benefit balance |
|
| I. Is sufficiently consistent with relevant EU policies and other EU legislation |
|
| J. Is as aligned as possible to international sustainability standards given the CSRD requirements |
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| Please share any comments and suggestions for improvement you might have relating to the above questions, referring explicitly to the part of the question you are providing comment |
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| Q49: Please, rate to what extent do you think ESRS G1 – Governance, risk management and internal control |
| A. Covers sustainability information required by articles 19a and 19b of the CSRD proposal (see Appendix II for CSRD detailed requirements) |
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| B. Supports the production of relevant information about the sustainability matter covered |
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| C. Fosters comparability across sectors |
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| D. Covers information necessary for a faithful representation from an impact perspective |
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| E. Covers information necessary for a faithful representation from a financial perspective |
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| F. Prescribes information that can be verified / assured |
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| G. Meets the other objectives of the CSRD in term of quality of information |
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| H. Reaches a reasonable cost / benefit balance |
|
| I. Is sufficiently consistent with relevant EU policies and other EU legislation |
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| J. Is as aligned as possible to international sustainability standards given the CSRD requirements |
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| Please share any comments and suggestions for improvement you might have relating to the above questions, referring explicitly to the part of the question you are providing comment |
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| Q50: Please, rate to what extent do you think ESRS G2 – Business conduct |
| A. Covers sustainability information required by articles 19a and 19b of the CSRD proposal (see Appendix II for CSRD detailed requirements) |
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| B. Supports the production of relevant information about the sustainability matter covered |
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| C. Fosters comparability across sectors |
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| D. Covers information necessary for a faithful representation from an impact perspective |
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| E. Covers information necessary for a faithful representation from a financial perspective |
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| F. Prescribes information that can be verified / assured |
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| G. Meets the other objectives of the CSRD in term of quality of information |
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| H. Reaches a reasonable cost / benefit balance |
|
| I. Is sufficiently consistent with relevant EU policies and other EU legislation |
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| J. Is as aligned as possible to international sustainability standards given the CSRD requirements |
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| Please share any comments and suggestions for improvement you might have relating to the above questions, referring explicitly to the part of the question you are providing comment |
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| Q51: to what extent do you support the implementation of Application Provision AP1? |
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| Q52: to what extent do you support the implementation of Application Provision AP2? |
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| Q53: what other application provision facilitating first-time application would you suggest being considered? |
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| Please explain why |
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| Q54: for which one of the current ESRS disclosure requirements (see Appendix I) do you think implementation feasibility will prove challenging? and why? |
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| Given the critical importance of implementation prioritisation / phasing-in, please justify and illustrate your response |
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| Q55: over what period of time would you think the implementation of such “challenging” disclosure requirements should be phased-in? and why? |
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| Given the critical importance of implementation prioritisation / phasing-in, please justify and illustrate your response |
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| Q56: beyond feasibility of implementation, what other criteria for implementation prioritisation / phasing-in would recommend being considered? And why? |
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| Given the critical importance of implementation prioritisation / phasing-in, please justify and illustrate your response |
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| Q57: please share any other comments you might have regarding ESRS implementation prioritisation / phasing-in |
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| If you have other comments in the form of a document please upload it here |
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