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Deloitte & Associés

Deloitte & Associés, société de commissaires aux comptes, est l'une des structures juridiques de Deloitte France.

Lobbying Activity

Response to Initiative on EU taxonomy - environmental objective

3 May 2023

On behalf of Deloitte (1), we are pleased to provide feedback on the draft EU Taxonomy Environmental Act and Amendments to the Taxonomy Climate and Disclosures Delegated Acts. The accompanying pdf file includes our full cover letter as well as detailed comments and suggestions related to some specific technical points of the draft EU Taxonomy Environmental Act and amendments to the Taxonomy Climate and Disclosures Delegated Act. In addition to these technical matters, we wish to bring the three following points for your consideration. Whilst we appreciate the constraints, having only four weeks to comment on critical draft delegated acts, such as these, is insufficient time for constituents to digest and comment meaningfully on what are important public interest matters. The feedback and experience on the existing Climate and Disclosures Delegated Acts is that much greater stakeholder engagement is required to deliver effective regulation that will drive the meaningful change that is required. Resultantly, please note that we were not able to conduct an exhaustive in-depth review of the information contained in the drafts Delegated Acts and Annexes. We share comments only on certain technical matters which we identified as requiring further clarity at first glance, to ensure implementation feasibility, consistency, reliability, and auditability. We do not express any views on the other parts of the Delegated Acts on which we have not commented. Even with transitional relief, the proposed less than 12-month period between the date of adoption by the Commission of the Delegated Acts and their application is too short and likely to be unworkable. Companies are still struggling to implement the first two Climate and Disclosures Delegated Acts. Besides, the implementation of the draft Delegated Acts will be concomitant with significant projects currently underway, notably the upcoming ESRS sustainability reporting. A coordinated approach is needed to deliver a coherent package on ESRS and Taxonomy reporting. The European Commissions goal of reducing and simplifying companies reporting requirements indicated in the Long-term competitiveness of the EU: looking beyond 2030 (2) would suggest that the reduction is performed in a consistent way such that the associated reporting requirements under ESRS are considered in parallel with the Taxonomy. If you have any questions or you would like to discuss our comments, please reach out the contacts indicated in our attached cover letter. Yours Sincerely (1) For more information, see the link to Deloitte global website (https://www.deloitte.com/global/en/about/governance/network-brand-alliances/about-the-network.html?icid=bottom_about-deloitte) (2) European Commission Com(2023) 168 of 16 March 2023 - Communication_Long-term-competitiveness.pdf (europa.eu) (https://commission.europa.eu/system/files/2023-03/Communication_Long-term-competitiveness.pdf)
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Response to Initiative on EU taxonomy - environmental objective

3 May 2023

On behalf of Deloitte (1), we are pleased to provide feedback on the draft EU Taxonomy Environmental Act and Amendments to the Taxonomy Climate and Disclosures Delegated Acts. The accompanying pdf file includes our full cover letter as well as detailed comments and suggestions related to some specific technical points of the draft EU Taxonomy Environmental Act and amendments to the Taxonomy Climate and Disclosures Delegated Act. In addition to these technical matters, we wish to bring the three following points for your consideration. Whilst we appreciate the constraints, having only four weeks to comment on critical draft delegated acts, such as these, is insufficient time for constituents to digest and comment meaningfully on what are important public interest matters. The feedback and experience on the existing Climate and Disclosures Delegated Acts is that much greater stakeholder engagement is required to deliver effective regulation that will drive the meaningful change that is required. Resultantly, please note that we were not able to conduct an exhaustive in-depth review of the information contained in the drafts Delegated Acts and Annexes. We share comments only on certain technical matters which we identified as requiring further clarity at first glance, to ensure implementation feasibility, consistency, reliability, and auditability. We do not express any views on the other parts of the Delegated Acts on which we have not commented. Even with transitional relief, the proposed less than 12-month period between the date of adoption by the Commission of the Delegated Acts and their application is too short and likely to be unworkable. Companies are still struggling to implement the first two Climate and Disclosures Delegated Acts. Besides, the implementation of the draft Delegated Acts will be concomitant with significant projects currently underway, notably the upcoming ESRS sustainability reporting. A coordinated approach is needed to deliver a coherent package on ESRS and Taxonomy reporting. The European Commissions goal of reducing and simplifying companies reporting requirements indicated in the Long-term competitiveness of the EU: looking beyond 2030 (2) would suggest that the reduction is performed in a consistent way such that the associated reporting requirements under ESRS are considered in parallel with the Taxonomy. If you have any questions or you would like to discuss our comments, please reach out the contacts indicated in our attached cover letter. Yours Sincerely (1) For more information, see the link to Deloitte global website (https://www.deloitte.com/global/en/about/governance/network-brand-alliances/about-the-network.html?icid=bottom_about-deloitte) (2) European Commission Com(2023) 168 of 16 March 2023 - Communication_Long-term-competitiveness.pdf (europa.eu) (https://commission.europa.eu/system/files/2023-03/Communication_Long-term-competitiveness.pdf)
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Meeting with Mario Campolargo (Director-General Informatics)

2 Feb 2022 · Digital Transformation in Public Administration – exchange of views

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

30 Apr 2021 · Record of a podcast serie Insights on responsible business

Meeting with Carole Mancel-Blanchard (Cabinet of Commissioner Elisa Ferreira)

27 Jan 2021 · Shaping the future of EU Cities Remark: Interview by Deloitte Portugal

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

21 Oct 2020 · Speech at online's Deloitte EU Green Deal Lab

Meeting with Gertrud Ingestad (Director-General Informatics)

1 Oct 2018 · Future of Regulation

Meeting with Vivian Loonela (Cabinet of Vice-President Andrus Ansip)

12 Sept 2016 · Cyber security