EFRAG is consulting on the Exposure Draft of the European Sustainability Reporting Standards for SMEs (ESRS LSME ED – CSRD art. 19 a 6) that are public-interest entities, small non-complex credit institutions (in short, SNCI or SNCIs), and captive insurers and re-insurers (collectively referred to as “LSME” or “LSMEs”).
A questionnaire has been prepared to support the collection of public feedback in the consultation and can be found
here
This field test is conducted in parallel with the public consultation and intends to complement the outcome of the consultation, with additional fact-based evidence. The purpose is to gather facts and evidence on the challenges and benefits of the content of the ED, from stakeholders that will prepare actual disclosures applying ESRS LSME ED.
From the preparers’ perspective, the participation to the field test may take two forms:
a) Actual preparation of (or part of) the disclosures in ESRS LSME ED, respond to the Field Test Questionnaire and participation to workshops and/or interviews with the EFRAG Secretariat; or
b) Preparation (such as assessment of the challenges and benefits deriving from the disclosures in ESRS LSME ED, supported by the Field Test Questionnaire) and participation to workshops and/or interviews with EFRAG Secretariat.
While the second approach is less strenuous, EFRAG encourages preparers to follow the first approach as far as possible as it will provide significantly more useful information.
From the users’ perspective, the participation to the field test requires preparation and participation to workshops and/or interviews with EFRAG Secretariat.
The Field Test focuses on the following key elements:
(a) The costs and challenges associated with each of the disclosures required;
(b) The proportionality and relevance of the proposed disclosure requirements;
(c) The understandability of the guidance provided in the ED and its ability to support the implementation of the disclosure requirements;
(d) The expected benefits of the disclosures.
The questionnaire contains the following modules:
• General, strategy, governance and materiality assessment (ESRS LSME Section 2);
• Policies, actions and targets (ESRS LSME Section 3);
• Social (ESRS LSME Section 5); and
• Business conduct (ESRS LSME Section 6).
The application of Section 1 General Requirements form part of the consideration of the modules.
A prerequisite to participation in the field test is the completion of the consultation questionnaire as well as the field test questionnaire. This means that all the questions in the consultation questionnaire related to the selected module(s) need to be answered and may be further discussed in the workshops/interviews.
Mocked- up sections of sustainability statement would be very welcome but are not required (approach a) versus b) on the previous page).
All information provided will be treated confidentially and it may be shared with the consultant assisting with the Cost Benefit Analysis. The results of the Field Test will be published on an anonymised basis.
After analysis of the responses, the results will be discussed at workshops jointly with other preparers and users that participate to the field test discussion to validate the outcomes from the field test, as well as to ensure a full understanding of responses. The workshops are planned for the first half of May 2024. The results from the test will then be presented to the EFRAG SRB and EFRAG SR TEG and considered as part of the consultation material.
EFRAG is looking for preparers (with or without prior experience in sustainability reporting) included in the following categories in scope of the Corporate Sustainability Reporting Directive (CSRD) that can opt for the derogation from ESRS for large undertakings and instead apply the simplified ESRS LSME:
- small undertaking with securities listed in EU regulated markets
1
- medium undertaking with securities listed in EU regulated markets
- small non-complex financial institution
2
- captive insurance or reinsurance undertaking as preparer of an ESRS report (LSME)
3
- third country listed SMEs that are in scope of ESRS LSME ED as preparer of an ESRS report (LSME)
4
EFRAG is looking for participants that allow for a balanced coverage of countries in the European Economic Area and sectors.
For further information, please contact
LSME@efrag.org.
Please complete the selected modules for this questionnaire and the corresponding questions in the consultation questionnaire by
21 April 2024.
Survey instructions
Some questions in the survey will appear depending on your previous answers or choices. You will now be able to save your responses before final submission.
If you have no opinion on a question you can skip the question.
Please note that EFRAG only considers completed surveys - partial submissions are ignored. You will receive an email with your response on submission.
1 Small and medium-sized undertaking within the meaning of Article 3(2) and (3) of Directive 2013/34/EU which are public-interest entities as defined in point (a) of point (1) of Article 2 of that Directive and which are not micro-undertakings as defined in Article 3(1) of that Directive
2 As defined in point (145) of Article 4(1) of Regulation (EU) No 575/2013
3 As defined in point (2) and (5) of Article 13 of Directive 2009/138/EC of the European Parliament and of the Council
4 According to Art. 4(5) of the Transparency Directive (as amended by the CSRD)