IOGP input to the IIA on the EC’s Delegated Regulation on taxonomy-related disclosures by undertakings reporting non-financial information

September 2020

This document provides IOGP’s input to the Impact Inception Assessment on the European Commission’s Delegated Regulation on taxonomy-related disclosures by undertakings reporting non-financial information.

Context

Reporting on taxonomy-compliant activities will require companies to review their processes and establish new systems and reporting functionalities. The new requirements will likely create additional external and internal costs.

IOGP fully recognises the necessity to advance measures to drive the sustainable transition. However, to ensure that the Taxonomy Regulation works in practice and will achieve its objectives, we call on the European and national authorities to support the industry in the implementation and enforcement of these very new rules and requirements.

Key Points

  • One of the options to ensure flexibility is to extend the timeline for the disclosure obligation or retain the principal of one or two pilot years. This phased-in approach could be deployed until all delegated acts on six environmental objectives are adopted by the EU institutions
  • Alignment across existing and upcoming legislation is key: we call on the Commission to introduce a clear policy planning framework with well-sequenced, realistic timelines
  • The upcoming delegated act should focus on minimum requirements, rather than being too prescriptive and potentially duplicating indicators
  • Transitional activities play a crucial role in helping the EU deliver its climate and energy objectives: clear guidelines for the reporting on transitional activities should be provided
  • We call on the Commission to carry out a detailed and guided-by-experience impact assessment, and we encourage the Commission to reflect on the “‘One-In, One-Out’ (OIOO) principle “to cut red tape” in the upcoming impact assessment

Overview

  • Introduction
  • Set workable timelines to achieve comprehensible reports
  • Ensure coherence between different tools
  • Adopt a flexible approach and include indicators for specific transitional activities
  • Adequate impact assessment and adherence to the Better Regulation principles need to be guaranteed
  • Final remarks

Author

IOGP

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