Ambitious reporting requirements for sustainable transformation
It is a key priority for the Danish Government to enable the green and sustainable transformation. The Danish
government has set an ambitious target to reduce greenhouse gas emissions by 70 % in 2030 as well as
protect the environment in accordance with the United Nations Sustainable Development goals. Capital and
investment are necessary in order to finance transformation at the company level. Leaders at Davos 2020
underlined this
–
investment and finance will increasingly be directed towards sustainable activities. We need
to make sure that European businesses are optimally equipped to attract the increasing amount of green and
sustainable investment funds both at the European level, but also at the global level.
Danish priorities
An ambitious and sustainable revision of the NFRD should rest on the following key priorities:
Differentiated levels of reporting
The Danish Government supports an ambitious approach to ESG-reporting that includes reporting on
emissions and climate and environmental footprints in order to facilitate a sustainable transformation of our
economy and society. Different levels of requirements depending on company size and resources can ensure
reporting tailored to expected ability. The Commission should be encouraged to look at a three-level
regulation:
First level,
keeping the
full set of requirements
including the reporting requirements for non-
financial companies in the Taxonomy Regulation for the current scope of the NFRD.
Second level,
introducing a set of
minimum core requirements focused on ESG reporting
on a set of
relevant KPI´s for the public interest companies with 100 to 500 employees and large companies
which should seek to achieve coherence with the requirements under the Disclosure regulation.
Third level,
voluntary simplified standards for SMEs
with a core of ESG indicators aligned with
reporting requirements in the Disclosure Regulation to the extent possible. The criteria of the scope
of each level should be clear and clear guidance should be provided for companies
–
especially for
SMEs.
Structure and digitalization
Accessibility and transparency of non-financial information should be strengthened which will make it easier
to find and compare specific information. All non-financial companies in Denmark starting from 2012 have
reported their annual reports digitally. The transition from printed annual reports to digital reports have been
smooth. Both for the companies reporting, the users of the information, and the authorities who will all get
a better overview of information and benefit from the easy, digital access. Looking forward, there is a great
potential in exploring possibilities for
making non-financial information digital
.
Disclosures on policies
The disclosure requirements regarding policies on ESG should be updated to ensure that the reported
information is value-creating for users of the non-financial information. They must also be clear and
obvious so the companies understand what information they are expected to report. A set of more specific
requirements to the content of policy reporting should be introduced in order to ensure the disclosures are
verifiable, relevant, recent and contributes to a fair, balanced and understandable report.
Non-financial standard setting in the EU
European standards can be a step in the right direction to reach the long-term goal of a global standard.
Alignment between the NFRD, the reporting requirements of the Disclosure and Taxonomy Regulation and
the guidance/standard must be ensured. The work done in regard to standards and guidance for companies
must enable digital solutions and a future standard should take the vast possibilities from
digital reporting
into account.