IOGP response to the consultation on ESG disclosures under Regulation (EU) 2019/2088

This document provides IOGP’s response to the consultation paper laying out the proposed Regulatory Technical Standards (RTS) on content, methodologies and presentation of disclosures under the Sustainable Finance Disclosure Regulation (SFDR).

Context

IOGP welcomes the opportunity to provide its feedback to the joint European Supervisory Authorities (ESAs) consultation paper on ESG disclosure since the SFDR disclosure obligations for financial market participants might influence IOGP member companies’ non-financial reporting.

Key Points

• It is of great importance to ensure alignment between the disclosure obligations under different pieces of legislation (e.g. Taxonomy Regulation, NFRD, SFDR) to avoid any overlap or duplication of reporting obligations
• The development of the Regulatory Technical Standards (RTSs) stemming from the SFDR should be developed in line with the review of the NFRD
• IOGP believes the RTS should be based on current EU legislation on non-financial reporting and remain flexible to guarantee future alignment with the revised NFRD