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France was the first EU member state to transpose CSRD in Dec 2023 and the ANC has done a remarkable job of providing guidance to French companies on the ESRS.<\/p>\n
ANC encourages us to \u201cnot lose sight of what’s essential: establishing robust standards applying to the communication of economic players means having the common language needed to understand each other and thus be able to make the right decisions\u201d.<\/p>\n
ANC proposes 4 measures. The first 2 can be summarized as follows:<\/p>\n
\u2b55 Introduce more proportionality into the reporting requirements<\/p>\n
\u27a1\ufe0f Increase the size threshold, to take into account the specificities of \u201cintermediate-sized\u201d companies.<\/p>\n
The European definition of a \u201clarge company\u201d covers a large number of mid-sized companies, and the notion of \u201cintermediate-sized\u201d, does not exist in European law.<\/p>\n
Adopting thresholds consistent with that of the CS3D (1,000 employees and \u20ac450m turnover) would therefore be a reasonable solution.<\/p>\n
\u27a1\ufe0f Reduce the scope by adapting and extending the LSME standards to these \u201cintermediate-sized\u201d companies (except if they are PIE companies with >500 and turnover >\u20ac50m).<\/p>\n
Compared to the current ESRS, the LSME draft standards for listed SMEs simplify reporting by reducing the number of potential disclosures.<\/p>\n
Given the broader scope of the companies concerned, they should then be subject to a new review and to a consultation.<\/p>\n
\u27a1\ufe0f Postpone the application by 2 years, to FY 2027 (publication 2028), for these \u201cintermediate-sized\u201d companies, (except if they are PIE companies with >500 and turnover >\u20ac50m).<\/p>\n
However, such a revision should be finalized very quickly, so as not to put at odds the many member States that have faithfully transposed the CSRD.<\/p>\n
\u2b55 Advance the review of the relevance of ESRS Set 1 for very large companies<\/p>\n
The review is currently programmed for 2029 as stipulated in CSRD.<\/p>\n
It should be advanced, but needs to be based on the lessons learned from the first sustainability statements that will have been produced and audited.<\/p>\n
Taking into account the need for public consultation, in practice, this means 3 financial years with the current standards: 2024, 2025 and 2026.<\/p>\n
To alleviate constraints, however, it is possible to extend the current transitional arrangements provided for in the ESRS by an additional year so that they do not end prematurely.<\/p>\n
Source : ANC on LinkedIn >><\/a><\/p>\n \u2014<\/p>\n Stay tuned for more CSRD and ESRS insights.<\/p>\n