Response on the Non-Financial Reporting Directive

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The review of the Non-Financial Reporting Directive should focus on strengthening and harmonising provisions. Disclosure obligations on listed issuers should be comparable, well-calibrated and proportionate.

We would caution against increasing non-market-related disclosure obligations on listed issuers alone as this would risk disincentivising companies from listing on Regulated Markets, which would not increase transparency. It is important that these disclosures also apply to private firms with comparable economic, social, and environmental footprints to meet the Commission’s objective of reorienting private capital flows towards more sustainable investments.

The scope and targets of policy measures related to sustainability need to remain detached from the type of financing a company has opted for. The same rules should apply to companies, whether they have opted for debt or equity financing. We would support the introduction of specific proportionate voluntary guidelines for SMEs. This would cater to the need for transparency for investors but place a more proportionate burden in terms of costs for SMEs that are an important part of capital markets. We consider that digitisation is key to enabling a broad and efficient use of non-financial data provided by the NFRD.