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European Contact Group

ECG

The European Contact Group (ECG) brings together the six largest professional services networks in Europe: BDO, Deloitte, EY, Grant Thornton, KPMG and PwC.

Lobbying Activity

Meeting with Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque), Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

11 Dec 2025 · Working dinner

Response to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies

26 Mar 2025

The European Contact Group (ECG) is pleased to provide its feedback on the Commissions proposed amendments to the Taxonomy Disclosure Delegated Act (DDA), the Climate Delegated Act (CDA) and the Environmental Delegated Acts (EDA) (the consultation). We share our main comments in the attached letter, with detailed comments in the enclosed appendices A (comments on the proposals and other recommendations) and B (editorial suggestions).
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Response to Templates for voluntary post-issuance disclosures for issuers of green bonds or sustainability-linked bonds

28 Jan 2025

The European Contact Group (ECG) welcomes the opportunity to provide feedback on the European Commission draft delegated regulations relating to external reviewers of European Green Bonds (EU GB). In responding, we aim to contribute to workable and balanced rules for this new supervisory regime and to support a framework which encourages the supply of external reviewers in the market for EU GBs. Regarding the draft rules of procedure for the exercise of ESMAs power to impose fines or periodic penalty payments, we would like to share the following practical suggestions and requests for clarity: Article 1.3: a reasonable time limit should be specified in the delegated regulation for the person subject to investigations to respond through written submissions to a draft statement of findings Article 2.4: the person subject to investigations should in any event have at least four weeks to make written submissions to ESMA, regardless of whether ESMA agrees or not with all or some of the findings of the investigating officer Article 2.6: there should be a deadline for ESMA to either impose a penalty or close the matter Article 3.1: again, a minimum period of time should be specified by the delegated regulation for a person subject to investigations to respond through written submissions to a statement of findings Article 5.1: ESMA shall, upon request, grant access to the file to the person subject to the investigations following notification of any statements of findings. Would a draft statement of findings qualify? If so, this could be explicitly stated. If not, in our view it should be included, to respect the rights of defence of the person subject to the investigations Regarding the draft delegated regulation on fees to be charged by ESMA to external reviewers of EUGB, we would like to share the following comments and requests for clarity: The level of registration fees and annual supervisory fees seems high. Given that this is an emerging market and registrants may often be individual companies and not parent/group entities these costs could pose a significant barrier to market entry. As a result, there is a risk that the market may fail to attract a diverse range of providers. The two-year exemption from annual supervisory fees may not be a long enough period for small new entrants to the market Article 3: it should be clarified that the applicable turnover used to calculate annual supervisory fees refers to the turnover relating to the provision of external review services for European Green Bonds In the Annex to the draft delegated regulation , the template "TEMPLATE FOR PERIODIC POST-ISSUANCE DISCLOSURES FOR SUSTAINABILITY-LINKED BONDS (ALLOCATION REPORT)" contains in the title the specification "ALLOCATION REPORT" which seems to suggest that, for sustainability linked bonds whose issuers decide to voluntarily use these templates, a reporting on how the proceeds of these type of bonds have been allocated is needed. In our view, this seems to go against the nature of this type of bond which is not a "use of proceeds" bond and when issued under other market-based principles (ICMA SLBPs) does not require an allocation report per se.
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Response to Tackling the role of enablers involved in facilitating tax evasion and aggressive tax planning in the European Union

12 Oct 2022

The European Contact Group (ECG) which brings together the six large professional Services networks in Europe (BDO, Deloitte, EY, Grant Thornton, KPMG and PwC), welcomes the opportunity to respond to the EC Call for Evidence on Securìng the Activity Framework for Tax Enablers. Please see attached our letter.
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Meeting with Barry Andrews (Member of the European Parliament)

15 Jun 2022 · EU regulatory environment

Response to Strengthening the quality of corporate reporting and its enforcement

4 Feb 2022

The European Contact Group (ECG), which brings together the six large professional services networks in Europe (BDO, Deloitte, EY, Grant Thornton, KPMG and PwC) welcomes the opportunity to respond to the call for evidence of the European Commission for the initiative on ‘Corporate reporting - improving its quality and enforcement’. Please find attached a list of studies and reports with information and evidence supporting the arguments made in the ECG comment letter, as well as recent articles of relevance to the initiative. The studies have been summarised and linked for convenience of the reader.
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Response to Revision of Non-Financial Reporting Directive

14 Jul 2021

Please see attached the comment letter from the European Contact Group.
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Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

30 Jun 2021 · Videoconference - Discussion green taxation and the role of the audit profession