FAQ on ESG

Detailed reporting with regard to the ESG (environmental, social, governance) factors of companies is becoming increasingly important. In addition to an increased awareness of the topic of sustainability in society as a whole, investors in particular are interested in the development of non-financial data. Through increasing reporting obligations, companies and financial market participants have to disclose the extent to which their corporate actions affect the environment and society, and to what extent there are opportunities for optimization.

In this context, the EU Commission is primarily aiming at greater transparency and quality in reporting in order to offer investors more security. The proposal to revise Directive 2014/95/EU could now help in this regard. Proposal for the revision of Directive 2014/95/EU

On April 21, 2021, the proposals of the EU Commission for a revision of the CSR Directive 2014/95/EU ("Directive on the disclosure of non-financial information") were published. These are primarily aimed at increasing the transparency of companies in the sustainability area as well as the development of a comprehensive sustainability report.

Here you can find the complete draft of the EU Commission

To give you a complete overview of the upcoming changes, we have answered all the important questions briefly and compactly in this blog post:

Issue/Question

Solution/Answer

501

When are the regulations expected to apply?

The member states envisage that the proposed regulations will be applied to financial years beginning on or after January 1, 2023. As of January 1, 2026, sustainability-related reporting requirements are then also to apply to capital market-oriented small and medium-size enterprises.

502

Which content-related reporting fields are necessary?

Through Directive 2014/96/EU, companies have so far been required to report at least on environmental, social and employee issues, respect for human rights and the fight against corruption and bribery. These reporting fields remain in place, but are to be increasingly geared towards anchoring sustainability aspects and indicators in the company's strategy and management system. What is new, however, is the reporting with regard to corporate governance. The so-called corporate governance factors are intended to provide information on the role of the administrative, management and supervisory bodies and relevant sustainability aspects in this respect, the composition of such bodies and the internal control and risk management systems of a company.

503

Who is affected by the new regulations?

The original proposed amendment required all listed companies and companies with more than 250 employees to provide comparable audited disclosures in inline XBRL/ESEF format. However, the update of the Non-Financial Reporting Directive (NFRD) by the Council of the European Union results in a change regarding the new disclosure requirements for companies. Private companies with more than 250 employees are now exempt from the requirement to provide disclosures in inline XBRL format, while the ESEF requirements for public companies remain in place.

504

What are the reporting formalities and where will the report be anchored?

Reporting is to be done in a standard electronic format according to ESEF Regulation (EU) 2019/815 for financial statements and management report. Therefore, the information is to be prepared in XHTML format and labeled according to a taxonomy. The corresponding categorization system is still being developed.

505

What are the practical implications of the amendments?

The implementation of the currently available amendment proposals would be of great importance for sustainability reporting and potential users. Companies therefore face a variety of challenges in the future. The expansion of the scope with regard to ESG reporting, the digital availability of the sustainability report as well as the redesign of the content and the external audit requirement for the sustainability report. The new CSR Directive also follows a dual materiality perspective. This means that companies must record the effect of sustainability aspects on the economic situation of the company and clarify the impact of operations on sustainability aspects.

506

Is it technically possible to merge two separately created, valid XHTML documents with iXBRL into one common XHTML document?

Yes, this is possible with the XBRL Tagger ("Merge iXBRL"). However, it is not yet clear whether this should be necessary at all, as the CSRD reports must be included in the Management report.

507

What happens to the iXBRL instances that were valid before merging?

These should still be valid.

508

Will the new document created by merging and containing both taxonomies be validated again with both taxonomies?

Yes, exactly.

509

Do you have any initial findings on the creation of a taxonomy to deal with CSRD content? Can you already see any tendencies as to whether this will be a separate taxonomy or if it will be integrated into the ESEF core taxonomy?

Yes, EFRAG will most likely create a separate XBRL taxonomy. The XBRL Tagger allows you to load and tag multiple taxonomies at the same time.

   Proposal for the revision of Directive 2014/95/EU
       When are the regulations expected to apply?
       Which content-related reporting fields are necessary?
       Who is affected by the new regulations?
       What are the reporting formalities and where will the report be anchored?
       What are the practical implications of the amendments?
       Is it technically possible to merge two separately created, valid XHTML documents with iXBRL into one common XHTML document? 
       What happens to the iXBRL instances that were valid before merging? 
       Will the new document created by merging and containing both taxonomies be validated again with both taxonomies? 
       Do you have any initial findings on the creation of a taxonomy to deal with CSRD content? Can you already see any tendencies as to whether this will be a separate taxonomy or if it will be integrated into the ESEF core taxonomy?

Siehe auch

FAQs, Validation Messages and Other Known Issues

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