Questions and answers about ESRSs

October 30, 2023
Piotr Biernacki
Sustainability Managing Partner
EFRAG has launched a Q&A platform for ESRS standards. It allows anyone to submit questions and concerns about the application of the new standards and receive answers. How will this system work and what will it be useful for?

The Q&A platform has been available since October 24. at this address. However, in this document you can familiarize yourself with the process according to which individual questions will be handled.

Each question submitted to EFRAG will be assigned to one of five categories:

  1. Explanation (clarification): EFRAG will prepare answers to these questions and publish them on its website. This category will include rather narrow questions requiring an indication of which provision of the standards should be used and how.
  2. Guidelines (guidance): these questions will be included in EFRAG's work plan for Implementation Guidance. These are broader documents covering cross-cutting topics. EFRAG is currently working on two sets of guidance (one on materiality testing and the other on the value chain). Questions of a broader, cross-cutting nature will fall into this category.
  3. Changes to ESRSs: If it turns out that a change to the content of a specific standard is required, the issue raised in the question will be included in EFRAG's work plan for changes to standards.
  4. Outside the scope of ESRS or EFRAG: questions that go beyond the ESRS standards themselves, e.g. concerning the CSRD directive or other EU legislation, will be forwarded to the European Commission.
  5. Refusal (rejection): rejection of a question by EFRAG. Questions may be rejected by EFRAG if they relate to a single company and the answer would not be useful to a wider audience, if their content is unclear, or if the issue has already been clarified.

All questions submitted via the Q&A platform will be recorded and published on the EFRAG website. Each question will be accompanied by a response or information on what EFRAG has done with the question (if it falls into one of the four categories mentioned above).

When preparing to ask a question, it is worth familiarizing yourself with the form used on the Q&A platform. It requires you to provide some information:

  • Identification of the person asking the question (this information will not be disclosed publicly)
  • Question content
  • Circumstances and facts related to the question (this is the context of the question, enabling EFRAG to better understand it)
  • Answers to a properly justified question; or alternative answers (it is not enough to ask the question itself; you must first consider possible answers to it and present them).
  • Arguments as to why we believe that the answer to this question may be important for a wider group of companies or stakeholders

The Q&A platform will therefore not be useful if our questions boil down to „How to prepare a report in accordance with ESRS,” „Who is subject to the CSRD directive,” or „How to calculate greenhouse gas emissions.” I would rather say that the platform is for advanced users who, despite having thoroughly studied the standards, have encountered doubts and challenges that they are unable to resolve on their own. There will certainly be many such situations in the first years of applying the new regulations. However, the interpretation database will gradually grow, and it will become easier for all of us to apply the new standards. Such a mechanism was sorely lacking in the first years of applying the EU Taxonomy; there are FAQs from the European Commission, but they are only updated once a year. It is good that in the case of ESRSs, the mechanism has been in place from the very beginning.

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