EUU, Alm.del - 2024-25 - Bilag 257: Notat, høringssvar og non-paper m.v. om Kommissionens høring om kommende horisontale indre markedsstrategi

Europaudvalget 2024-25
EUU Alm.del Bilag 257
Offentligt

Contributing to 25 % burden relief through automated reporting

Current annual recurring

costs from new regulation in

Denmark

Taxonomy

335 mill.

EUR

Potentials

for reductions in the EU

CSRD

1,5 bill.

EUR

Ecodesign

670 -1340 mill.

EUR

Bookkeeping

400 mill.

EUR

Electronic

invoicing

? bill.

DKK

Automated

Business

Reporting

–

applied broadly

? bill.

DKK

EPR

packaging

mill. EUR

Cyber

Resilience

24 - 32

mill. EUR

Automated

Sustainability

Reporting

? bill.

DKK

EUU, Alm.del - 2024-25 - Bilag 257: Notat, høringssvar og non-paper m.v. om Kommissionens høring om kommende horisontale indre markedsstrategi

Roadmap for enabling Automated Business and Sustainability Reporting

for a competitive Europe

To succeed with

streamlining

and automating

business

reporting

general …

EU regulations

and reporting

requirements to

‘fit for

digitalisation’

from the start

We need

to offer

structured and

standardized

digital data

formats to

companies

We need

to set minimum

requirements for

ERP-systems/

platforms etc.

offered in the

Single Market

We need

to establish a

common/interoperable

European open

data exchange

infrastructure

We need

…

while for

automating

sustainability

reporting

particular…

to develop

lacking ESG-

methodologies

We need

to establish free

access to emission

factors etc. for

companies

We need

EUU, Alm.del - 2024-25 - Bilag 257: Notat, høringssvar og non-paper m.v. om Kommissionens høring om kommende horisontale indre markedsstrategi

To succeed with streamlining and automating business reporting

in general…

EU regulations

and reporting

requirements to

‘fit for

digitalisation’

from the start

Problem:

Companies struggle to meet regulatory

reporting requirements digitally, despite

having the necessary systems, due to

difficult-to-interpret legislation.

Proposed solution:

The EU must ensure that legislation clarifies

what data companies need to report

digitally and make it easier to implement

digitally.

The EU should:

•

Before introducing new reporting

requirements under EU legislation, it

should be assessed whether reporting

requirements can be supported

digitally through automated

processes. This assessment can be

conducted by the Regulatory Scrutiny

Board.

We need

to offer

structured and

standardized

digital data

formats to

companies

Problem:

Companies often handle reporting data

and input data from their value chains and

to authorities in formats like PDFs, which

are not machine-readable causing obstacle

for automatization.

Proposed solution:

We need to offer structured and

standardized data formats so data can be

handled smooth and automatic by

companies in value chains.

The EU should:

•

When introducing regulation and

digital reporting requirements, the EU

should define common standards for

reporting formats and, where possible,

input data for reporting. It is crucial

that existing formats, such as XBRL

and CEF building blocks, are reused.

We need

to set minimum

requirements for

ERP-systems/

platforms etc.

offered in the

Single Market

Problem:

Many companies in the EU rely on a

multitude of systems for their operations,

each with its own distinct characteristics

and varying levels of quality and lack the

necessary functions for automation.

Proposed solution:

We need to set minimum requirements

for service providers to promote

automation and create a level playing

field.

The EU should

•

Allocate funds to promote digital

business systems for European

companies and reporting solutions for

authorities, contingent on meeting

minimum requirements for

interoperability and automation (e.g.

from the Digital Europe Programme)

•

Examine emerging business system

providers’ digital solutions to propose

legal minimum requirements for

methodologies, functionalities, data

standards, protocols, ownership,

integration, and portability. Draw

inspiration from existing regulations like

the Ecodesign Regulation.

We need

to establish a

Common

interoperable

European open

data exchange

infrastructure

Problem:

The way data is exchanged for reporting

and platforms varies, with some relying on

costly APIs. This fragmented approach

significantly increases companies'

workload. Input data is often transmitted

within closed proprietary networks.

Proposed solution:

EU can mandate standardized data

exchange protocols to streamline data

exchange.

The EU should:

•

Establish initiatives for common

standards for digital reporting,

including protocols for data

transportation and mandating the use

of CEF building blocks for cross-

border reporting and business data

exchange. This initiative aims to

facilitate seamless sharing of reporting

and business data across borders,

supported by funding opportunities

through calls for proposals.

We need

•

In addition, existing legislation should

be reviewed to identify reporting

requirements that can be simplified

through digitalisation and automation.

EUU, Alm.del - 2024-25 - Bilag 257: Notat, høringssvar og non-paper m.v. om Kommissionens høring om kommende horisontale indre markedsstrategi

…

while for

automating sustainability reporting

in particular

We need

to establish free

access to emission

factors etc. for

companies

We need

to offer structured

and standardized

digital data

formats to

companies

Problem:

Quality of data needed by companies for

reporting is low and fragmented - there

is lack of common data formats for

”input-data” for sustainability reporting.

Proposed solution:

We need to

offer structured and

standardized data formats,

so that data

can be handled more harmonized and

automatic by companies in value chains.

We need

to set minimum

requirements for

ESG-systems/

platforms etc.

offered in the

Single Market

Problem:

Companies need to move on from excel

sheets

–

and push to do so

–

but many

emerging digital ESG-solutions are

currently opaque and immature.

Proposed solution:

We need to consider

setting minimum

requirements for ESG-systems,

external data providers, platforms etc.

offered to companies in the Single

Market.

The EU should:

•

Examine the emerging landscape of

ESG-solutions, platforms and

systems, with a view to propose legal

minimum requirements for the use

and transparency of methodologies,

functionalities, data standards and

protocols used, data ownership,

integration-interfaces and

portability, etc. Inspiration could be

drawn e.g. from the adopted

Ecodesign Regulation requirement

on DPP service providers and the

proposal on CountEmissionEU, COM

2023(441) requirements for CO2-

calculation tools.

We need

to establish a

common/interoperable

European open

data exchange

infrastructure

Problem:

Emerging solutions and platforms often

promote data sharing in closed

proprietary networks.

Proposed solution:

We need a

common/interoperable

European open data exchange

infrastructure

(standards, protocols,

APIs, etc.) to

avoid vendor lock-in

for

companies’ data sharing.

The EU should:

•

Take initiative to establish a

common/interoperable European

open data exchange infrastructure

by mandating the utilizing of existing

building blocks e.g. the Connecting

Europe Facility’s e-Delivery

principles

for data sharing/reporting, as this is

key to keeping infrastructure truly

open and without vendor lock-in.

•

Supporting the establishment of the

infrastructure, possibly through a call

for proposals under a suitable

funding scheme.

We need

to develop lacking

ESG-methodologies

Problem:

Methodologies and standards for

assessing company performance in some

areas of sustainability are still lacking

(e.g., biodiversity).

Proposed solution:

We need to

engage in developing the

lacking methodologies

and standards

e.g. on biodiversity with a view to ensure

that they are “fit

for digitalization”.

Problem:

Estimations, average factors etc. are not

robust enough, are too limited and are

behind pay walls.

Proposed solution:

We need free and

easy access to

common emission factors

and other

similar secondary/public data needed by

companies for reporting.

The EU should:

•

Engage with companies to identify

where standards are lacking in order

to assess and report on the ESG-

topics covered by the ESRS-

standards (CSRD).

•

Facilitate and support the

development of lacking (global)

standards for methodologies needed

by companies in preparing their

sustainability report, e.g. on

biodiversity.

The EU should:

•

Supporting the development of a

first EU-set of emission factors which

can then be developed upon and

continuously updated going forward,

possibly through a call for proposals

under a suitable funding scheme, for

•

If necessary, propose a legal

framework for an emission factor

database with emission factors

needed for companies' assessment

of their carbon footprint in scope 1,

2 and 3, e.g. with inspiration from

the proposal on CountEmissionEU,

COM 2023(441).

The EU should:

•

Take initiative to develop standardised

data formats for sustatainability-

relevant data

–

data formats which can

be used for B2B data sharing and

collection towards sustainability

reporting.

•

A starting point could be e.g. to add

new standardised data fields for

fundamental product attributes to

eInvoices and eCatalogues on

standardised products codes (e.g.

UNSPSC, TARIC), physical units, CO2,

Digital Product Passport URL, etc.) to

increase quality and availability of data

needed by companies for reporting.