FuelsEurope and IOGP position on the Draft Delegated Regulation on taxonomy related disclosures by undertakings reporting non-financial information

FuelsEurope and IOGP appreciate the EU’s efforts to establish a sustainable finance framework that mobilises private funds to reduce greenhouse gas emissions and environmental impacts. Corporate reporting plays an important role in this endeavour.

Our industries support meaningful corporate reporting policies relating to the disclosure of non-financial information pertaining to sustainability.

Key Points

FuelsEurope and IOGP appreciate the opportunity to provide feedback on the draft delegated regulation supplementing Article 8 of the EU Taxonomy Regulation.

Our key observations:

• The cost, time and effort needed to comply with the Delegated Act should not be underestimated, and further efforts to optimise the reporting burden should be considered
• Phase-in of reporting should be extended by at least one year
• Simplify the disclosure tables to reduce reporting burden and focus on high value information
• To ensure efficient and consistent reporting of the KPIs, we recommend a simpler definition of the numerator and aligning the denominator with IFRS
• The proposed requirements for the CapEx plan give rise to administrative, competitive and legal concerns
• The list of accompanying disclosures is excessive and potentially conflicts with other aspects of financial and non-financial reporting
• The requirement to provide comparative data for previous reporting periods should be aligned with the rest of the financial statement
• The exclusion of investments in equity accounted ventures is likely to result in an understatement of companies’ true level of Taxonomy compliance
• Compatibility and coherence with existing and upcoming legislation

• Introduction
• Underestimation of effort: regulatory burden and cost
• Phase-in of Reporting: Ensuring a realistic implementation timeline
• Comparatives
• Disclosure tables
• Definitions
• Accompanying disclosures
• Compatibility and coherence with existing and upcoming legislation