European Confederation of Directors' Associations
ecoDa
The European Confederation of Directors' Associations (ecoDa) is a not-for-profit association founded in December 2004 under the laws of Belgium.
ID: 37854527418-86
Lobbying Activity
Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)
20 Jan 2026 · ESRS standards
Response to Postponement of deadlines within the Accounting Directive for the adoption of certain ESRS
18 Dec 2023
ecoDa is concerned about the ability of European companies targeted by the CSRD to meet all the legal requirements that will be imposed on them in an excessively short period of time. However, groups well advanced in sustainability reporting have indeed expressed a view that the overall implementation of the CSRD will benefit from early access to sector-specific standards so that the full scope of required information is addressed in the initial stages. ecoDa is therefore of the opinion that the public release of these standards within the deadlines initially announced (2026) will be welcomed by the market, with voluntary application encouraged until they become mandatory, with a requirement pushed by two years (2028). With respect to a two-year delay regarding sustainability information to be published by certain third country entities, the proposed decision should be clarified so that the two-year delay applies only to the sector-specific sustainability reporting obligations and not to the sector-agnostic sustainability reporting obligations. ecoDa would like to stress the necessity of a level-playing field for all entities in the EU markets as far as sustainability information is required, so EU entities are not at a disadvantage in terms of effort to comply, but also higher transparency (and exposure to environmental activism and litigation). Compliance in 2028 for sector-agnostic sustainability reporting obligations is already a delay compared to requirements for EU entities and should not be pushed again by another two years. ecoDa is taking this opportunity to express its concern on a more general subject. The likelihood that companies will not be able to provide all the data necessary to meet ESRS standards is high. The statements (qualifications) that will be used in the context of limited assurance should not generate concerns from the market (investors) as well as negative reactions from NGOs for companies. Raising awareness about the interpretation of this information by stakeholders would be necessary to preserve European competitiveness. Please consider our full opinion letter attached.
Read full responseMeeting with Lara Wolters (Member of the European Parliament, Rapporteur)
19 Jul 2023 · Staff level: CSDD Directive
Response to European Sustainability Reporting Standards
7 Jul 2023
1. ecoDa welcomes the opportunity to comment on the Draft Delegated Act on the first set of ESRS. ecoDa would like to thank EFRAG for its efforts in reducing the volume of information in a structured and thoughtful way. ecoDa approves the phase-in approach that will enable companies not previously concerned by sustainability reporting to take the time to get ready. 2. The formulation of standards allows companies to go beyond the minimum required. 3. ecoDa recommends that EFRAG quickly issue guidance and implementation schemes as well as feedback illustrating best practices, both from a qualitative standpoint (description) but also quantitative (presentation of tables), at the EU (preferably) and national levels. Tentative disclosure models (templates) could also be provided as illustrative examples when not already provided in the standards. Also, as companies or audit firms might interpret certain requirements differently, further guidance is also required for auditors to reach conclusions in case of inaccurate information which could reinforce the principle of materiality. If we want this information to be useful, the practice must focus on the important issues, so as to give board members tools to help the strategic and operational decision and prevent this reporting exercise from turning into a pure compliance exercise. For this purpose, the guidance must be clear for the companies, their advisers, and the auditors. 3. ecoDa commends the reaffirmation of the need to stick to the principle of double materiality, which is the only way to identify the impacts, risks, and opportunities and to inform the decisions of companies and councils for a real consideration of the sustainability issues 4. ecoDa would recommend issuing the non-financial reporting assurance guidance as quickly as possible. 5. ecoDa highlights the necessity to get effective and efficient internal control and risk management systems in place. To achieve the objectives, the use of a strong governance model such as the 3 Lines Model have to be considered. 6. EFRAG integrated the G dimension as part of the cross-cutting standards to align with the modifications made to CSRD but with a larger view of what G means, not purely corporate G (as in G1) but also as part of each of the topical ESRS. Even if the final outcome is currently reduced from the initial ambition, ecoDa is confident that the consistent relevance of the Governance issues in CSRD, could bring EFRAG to consider governance topics more broadly. 6. ecoDa thanks EFRAG for the opportunity to comment the Set 1 of ESRS. As the scope of the directive will extend to medium-sized companies for which the provision of the required information will demand a significant effort, things will need all the more to be put in motion without delay.
Read full responseResponse to Sustainable corporate governance
23 May 2022
Please find attached ecoDa's feedback.
Read full responseMeeting with Didier Reynders (Commissioner) and
30 Sept 2021 · Substainable Corporate Governance
Response to Fitness check on public reporting by companies
8 Mar 2018
Dear Madam, dear Sir,
The European Confederation of Directors’ Associations (ecoDa) would like to submit its preliminary reflection on the ongoing Fitness check on Corporate reporting that the commission is currently undertaking.
First an overall reflection regarding the timing of the Commission's initiative. At least parts of the regulation referred to as subject to the fitness check have only recently been implemented in the member states (as this was the case with the Non-financial Reporting Directive, for which 2017 was the first year of application for most companies when their financial year coincides with calendar year - and even later for companies with split financial year). Hence we question if the timing is right for an overall evaluation of the current regulation in this field. In general ecoDa is of the opinion that it takes at least about 3-5 years before the full effects of regulations of these kinds can be assessed with any reasonable degree of certainty.
This said, ecoDa would like to put forward the following brief comments:
1. Whether the current financial reporting framework meets its objectives and will continue to do so in the digital economy, whether the level of harmonisation and simplification meets the needs of respectively the large cross border groups and the SMEs:
As an overall consideration, ecoDa would like to underline the importance to avoid any disclosure requirements that may involve:
- listed companies be required to reveal business secrets, and
- unreasonable administrative burdens, especially for SMEs, thus risking to jeopardize the competitiveness of listed companies vs. their unlisted competitors.
2. Whether the financial and non-financial disclosures in the area of Environmental, Social and Governance (ESG) reporting by companies are fit for purpose, including as regards sustainability disclosures:
ecoDa considers that this is too early to judge, see introductory comment above.
3. Whether to encourage experimentation with integrated reporting as a way to make the EU reporting framework more effective and efficient and if yes how:
ecoDa questions if it is the Commission’s role to “encourage experimentation” among listed companies in this or other respects. ecoDa is of the general opinion that the development of new ideas and practices of corporate governance should primarily be left to the market, with the statutory regulator stepping in if and when such development leads to insufficient or inappropriate results.
4. Whether public corporate reporting does take enough consideration of – and at least is not a hindrance to – technological progress and how to make the best use of these new tools to do more:
It is certainly of great importance that statutory regulation is not a hindrance to the use of modern technology in public corporate reporting, but ecoDa fails to see any major problems with current regulation in this respect. And again ecoDa generally think it should be left to the market to develop adequate ways and means to comply with the regulation, including the use of modern technology for this purpose.
We hope these viewpoints may be of some value for the continued discussion of these matters. ecoDa intends to contribute even further to your more detailed upcoming consultation.
With best regards,
Per Lekvall Michel de Fabiani
Member of ecoDa’s Chair of the Policy Committee
Policy Committee
********************
About the European Confederation of Directors Associations (ecoDa)
The European Confederation of Directors Associations (ecoDa) is a not-for-profit association founded in December 2004 under the laws of Belgium. Through its national institutes of directors (the main national institutes existing in Europe), ecoDa represents approximately 55,000 board directors from across the EU.
Transparency Register: 37854527418-86
Read full response