In its opinion, the WPK welcomes the legislative initiative of the European Union on sustainability reporting within the context of the Corporate Sustainability Directive (CSRD).

It is also of the opinion that binding standards in this context help to improve the meaningfulness of sustainability reporting with respect to its targets and to make it easier to compare.

Opportunities for Improvement

The WPK sees these ESRS drafts as a good foundation that still needs further revision. The following opportunities for improvement were seen:

• Greater consideration of the SME perspective in the standard drafts,
• Clearer elaboration of the common theme and increasing the manageability of the standards,
• Delimitation and clarification of the group of stakeholders,
• Greater illustration of the concept of Double Materiality,
• Increasing the convergence between ESRS and the reporting standards of the ISSB.

The WPK hopes that its suggestions will be considered in the further standard-setting process and will be happy to be available for an exchange of opinion.