IOGP Europe responds to EFRAG’s consultation on sustainability reporting standards for non-EU groups (ESRS 40a)

IOGP Europe has submitted its response to EFRAG’s consultation on the draft ESRS 40a, on behalf of members falling within the scope of these standards.

ESRS 40a sets out the proposed sustainability reporting requirements for non-EU-headquartered groups with significant activities in the EU that fall within the relevant provisions of the Corporate Sustainability Reporting Directive (CSRD). The standards focus on companies’ impacts on people and the environment. Their development forms part of the wider work to implement CSRD requirements in the context of the Omnibus simplification agenda.

For international O&G companies operating across complex global structures and multiple reporting jurisdictions, clear and proportionate requirements are essential. Our response welcomes efforts to simplify reporting while recommending further refinements to make the standards workable in practice.

Our recommendations focus on:

• Clear reporting boundaries: Retain the mixed approach as an option for reporting EU-related impacts, with practical scoping requirements based on reasonably available information.
• Flexibility: Allow companies to select appropriate approaches at sub-topic level, while retaining the option to use consistent boundaries where this is clearer or less burdensome.
• Interoperability and equivalence: Facilitate the reuse of disclosures prepared under international frameworks, particularly ISSB standards, and recognise equivalent reporting regimes to avoid duplication.
• Legal certainty and workable assurance: Clarify expectations so that fair presentation and incorporation by reference do not create open-ended disclosure requirements or unnecessary reporting and assurance costs.