This paper builds on PRI’s extensive work on corporate disclosure and our response to the European Commission’s consultation on the review of the Non-Financial Reporting Directive. The PRI welcomes the extension of the scope of companies reporting under the CSRD to all large companies and all companies listed on regulated markets (except listed micro-enterprises). The paper contains three main recommendations:
- Co-legislators must ensure coherency between CSRD and SFDR reporting for financial market participants.
- The extension of scope to listed SMEs must be maintained, and the European Commission must undertake further research on how private SMEs, which are likely to enter situations of high risk, could be brought into the scope of the CSRD in a proportionate manner.
- Parent undertakings of subsidiaries, which are either large or listed SMEs, should be allowed to report certain sustainability information at the subsidiary level in their consolidated reports.
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