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Frank Bold Society

FBS

Frank Bold Society is a public interest law organisation protecting human rights and the environment.

Lobbying Activity

Meeting with Antonín Staněk (Member of the European Parliament)

2 Dec 2025 · Feedback on the Upcoming European Grids Package

Meeting with Pascal Canfin (Member of the European Parliament, Shadow rapporteur) and WWF European Policy Programme and ClientEarth AISBL

1 Dec 2025 · Omnibus I

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

27 Nov 2025 · ESRS and SFDR

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

17 Nov 2025 · Sustainability omnibus - update for civil society

Meeting with Sven Gentner (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and WWF European Policy Programme

5 Nov 2025 · Omnibus negotiations/ESRS revision

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

3 Nov 2025 · Sustainability omnibus - update for civil society

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur) and WWF European Policy Programme and

28 Oct 2025 · Sustainability omnibus and climate transition plans

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

2 Oct 2025 · Sustainability omnibus - update for civil society

Meeting with Martin Hojsík (Member of the European Parliament)

22 Sept 2025 · Energy grids, decentralized energy

Meeting with Pascal Canfin (Member of the European Parliament, Shadow rapporteur)

8 Sept 2025 · Omnibus I

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis) and ClientEarth AISBL and

18 Jun 2025 · Omnibus

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur for opinion)

3 Jun 2025 · Roundtable with ESG practitioners

Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur for opinion)

27 May 2025 · Omnibus (CSDD, CSRD)

Meeting with Lynn Boylan (Member of the European Parliament, Shadow rapporteur for opinion) and European Coalition for Corporate Justice

12 May 2025 · Omnibus Bill - attack on EU's human rights and sustainability laws

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur for opinion) and ClientEarth AISBL

12 May 2025 · Omnibus I

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

25 Apr 2025 · Sustainability Omnibus

Meeting with Christine Singer (Member of the European Parliament)

15 Apr 2025 · Omnibus

Meeting with Jörgen Warborn (Member of the European Parliament, Rapporteur)

8 Apr 2025 · Omnibus

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur) and European Coalition for Corporate Justice and Shift Project Limited

7 Apr 2025 · CSO exchange on sustainability omnibus

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné)

3 Apr 2025 · Simplification

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur for opinion)

2 Apr 2025 · Omnibus I

Meeting with Bas Eickhout (Member of the European Parliament, Shadow rapporteur for opinion)

2 Apr 2025 · Omnibus I

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and ClientEarth AISBL

24 Mar 2025 · Omnibus

Meeting with Pascal Canfin (Member of the European Parliament, Shadow rapporteur) and WWF European Policy Programme

24 Mar 2025 · Omnibus I

Meeting with Gabriele Bischoff (Member of the European Parliament) and Global Witness

20 Mar 2025 · Omnibus

Meeting with William Sleath (Director Secretariat-General) and Friends of the Earth Europe and

20 Feb 2025 · The Omnibus proposal regarding the CSRD, the CSDDD, and taxonomy

Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

20 Feb 2025 · Exchange on the upcoming Omnibus

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis), Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis) and

10 Feb 2025 · Simplification

Meeting with Lara Wolters (Member of the European Parliament, Shadow rapporteur)

31 Jan 2025 · Sustainability & Competitiveness (Event)

Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall) and ClientEarth AISBL and

29 Jan 2025 · Upcoming Omnibus proposal

Meeting with Mirzha De Manuel (Cabinet of Commissioner Valdis Dombrovskis), Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis) and

20 Jan 2025 · Exchange of views on the simplification policy

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

13 Jan 2025 · simplification omnibus

Meeting with Fiona Knab-Lunny (Cabinet of Commissioner Michael McGrath) and Human Rights Watch and

9 Jan 2025 · Meeting with a delegation of civil society organisations (CSOs) to discuss their concerns regarding the ‘omnibus’ initiative recently announced by President Von der Leyen.

Meeting with Pascal Canfin (Member of the European Parliament)

18 Dec 2024 · Simplification CSRD CSDDD

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and WWF European Policy Programme and

12 Dec 2024 · Sustainable corporate reporting

Meeting with Marie Toussaint (Member of the European Parliament)

11 Dec 2024 · Due diligence

Meeting with Martin Hojsík (Member of the European Parliament)

15 Nov 2024 · Corporate sustainability, ESGs

Meeting with Marie Toussaint (Member of the European Parliament) and WWF European Policy Programme

10 Oct 2024 · Sustainable finance

Meeting with Marie Toussaint (Member of the European Parliament)

4 Sept 2024 · CSRD and sustainable finance

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur)

12 Jan 2024 · EPRS - reporting standards

Response to Postponement of deadlines within the Accounting Directive for the adoption of certain ESRS

14 Dec 2023

Frank Bold welcomes the opportunity to provide feedback on the decision to postpone the draft Delegated Acts on the Sector Specific ESRS. Our response reflects the concerns discussed among members of the Alliance for Corporate Transparency, and its partners from business and investors communities. Not having promptly available sector specific standards for companies who will shortly start applying the sector agnostic ESRS represents a missed opportunity to make the reporting process less complex especially with regard to double materiality assessment and identification of material information. This is true particularly for first-time preparers and smaller companies. It will also result in less reliable and less comparable disclosures and thus will negatively affect the achievement of the objectives in the area of sustainability reporting. Although Frank Bold recognizes that current EFRAGs capacity - which is aggravated by the lack of sufficient funding from the European Commission - does not allow for the sector specific standards to be delivered by 2024, their content should be available with no further delay. We recommend: 1. A clear prioritisation within EFRAG of the sector specific standards work. The current EFRAGs workplan, which was developed pursuant to the European Commissions requests for prioritisation, envisages only 30% of time of EFRAG Sustainability Reporting Board and Technical Expert Group to be spent on sector-specific standards. Furthermore, developing guidance and standards for SMEs, including voluntary standards, has explicitly received a higher priority in the workplan, meaning that even the 30% envisaged for the sector-specific standards may not be met. We agree with the need for guidance, but the most effective way to deliver it is via the sector-specific standards. 2. The publication by EFRAG of exposure draft standards for high risk sectors as soon as available. 3. A staggered delivery of sector-specific standards: - Finishing 5 standards already under developments - (1) Oil and Gas + (2) Mining, Quarrying and Coal + (3) Road Transport + (4) Textiles, Accessories, Footwear and Jewellery + (5) Agriculture ready for adoption by June 2025 - Finishing additional 5 standards to reach coverage at least 10 high impact sectors to be adopted by EC by 2026; - Preparing the remaining 10 high impact sectors for adoption by 2027. Frank Bold strongly disagrees with the narrative underpinning the proposal that sector specific standards are an additional layer of legislative burden weighting on companies. Sector agnostic Reporting Standards already require companies to identify and report on sector-specific issues under an entity-specific regime. As such, sector specific standards bring legal certainty over topical issues to be disclosed. Secondly, Sector Specific Standards will simplify materiality assessment for preparers and their assurance by auditors, thus making the reporting exercise significantly less demanding and costly. At the same time, sector specific standards will guarantee that the outcomes of reporting from companies within the same sector are comparable and focused on the same issues. In conclusion, Frank Bold does not see valid reasons and evidence for the idea that sector specific standards will create a significant or undue reporting burden. On the contrary, sector-specific standards will make the reporting process clearer and more cost-effective for companies compared to the application of sector-agnostic standards alone. Therefore we urge that the European Commission requests and duly financially supports EFRAG to prioritise the development of the sector-specific standards. We call for gradual publication of the exposure drafts and adoption of the sector-specific standards for the 20 high risk and high impact sectors in 2025 (first 5), 2026 (additional 5) and 2027 (remaining 10).
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Meeting with Pascal Durand (Member of the European Parliament, Shadow rapporteur)

8 Dec 2023 · European Sustainability Reporting Standards (APA only)

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and Notre Affaire à Tous

16 Oct 2023 · CSRD

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur) and WWF European Policy Programme and

4 Oct 2023 · Environmental and climate due diligence

Meeting with Lara Wolters (Member of the European Parliament, Rapporteur) and ClientEarth AISBL

18 Sept 2023 · Staff level: CSDD Directive

Meeting with Tiemo Wölken (Member of the European Parliament, Rapporteur)

11 Sept 2023 · EU-Lieferkettengesetz (staff level)

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Katherine Power (Cabinet of Commissioner Mairead Mcguinness) and

18 Jul 2023 · European Reporting Sustainability Standards

Frank Bold urges mandatory climate and workforce reporting rules

7 Jul 2023
Topic — A consultation on new technical standards for corporate sustainability reporting under European law.
Message — Frank Bold calls for making climate and workforce metrics mandatory for all companies. They also demand removing voluntary labels for biodiversity and non-employee worker disclosures.12
Why — Standardized reporting would ensure high-quality data and reduce the burden on auditors.34
Impact — Investors and asset managers face a data gap, making sustainability due diligence harder.56
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Meeting with Marie Toussaint (Member of the European Parliament)

29 Jun 2023 · Corporate sustainable reporting

Meeting with Lara Wolters (Member of the European Parliament, Rapporteur)

14 Jun 2023 · Staff level: CSDD Directive

Meeting with Marie Toussaint (Member of the European Parliament)

30 May 2023 · Sustainability reporting - CSRD

Meeting with Pascal Durand (Member of the European Parliament)

26 Apr 2023 · ESRS (APA only)

Meeting with Pascal Durand (Member of the European Parliament)

4 Apr 2023 · ESRS (APA only)

Meeting with Pascal Canfin (Member of the European Parliament) and WWF European Policy Programme and

3 Apr 2023 · Green finance

Meeting with Marcel Kolaja (Member of the European Parliament, Shadow rapporteur for opinion)

23 Mar 2023 · discussion about provisions of the Media Freedom Act in the Czech context

Meeting with Marcel Kolaja (Member of the European Parliament, Shadow rapporteur for opinion) and Transparency International Liaison Office to the European Union and NFNZ – Nadační fond nezávislé žurnalistiky

27 Jan 2023 · discussion about provisions of the Media Freedom Act

Frank Bold Society urges stronger media transparency and independence

23 Jan 2023
Topic — The initiative aims to protect media freedom and pluralism within the European Union.
Message — They propose lowering transparency thresholds for local government advertising. They reject media exemptions on platforms and demand media board independence.123
Why — Stricter rules would help the organization achieve its goal of increasing government transparency.4
Impact — Political actors lose the ability to covertly influence regional media through advertising.5
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and Amnesty International Limited and

15 Nov 2022 · Corporate Sustainability Due Diligence

Meeting with Marie Toussaint (Member of the European Parliament, Shadow rapporteur)

11 Oct 2022 · Due diligence

Meeting with Sirpa Pietikäinen (Member of the European Parliament, Rapporteur for opinion) and World Wide Fund for Nature Belgium

27 Sept 2022 · Corporate Sustainability Due Diligence Directive

Meeting with Malte Gallée (Member of the European Parliament) and Global Witness and European Coalition for Corporate Justice

10 Jun 2022 · Due Diligence

Frank Bold demands tougher EU corporate sustainability and governance rules

23 May 2022
Topic — EU consultation on rules for companies to manage human rights and environmental impacts in supply chains.
Message — The organization wants the directive to align with international standards by focusing on risk severity. They argue for stronger legal duties for directors to oversee climate transition plans and sustainability strategies.12
Why — Tougher rules help the group use legal action to protect human rights and the environment.3
Impact — Companies using superficial compliance measures would face greater legal liability and stricter operational oversight.4
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Response to Updating the EU Emissions Trading System

8 Nov 2021

Frank Bold Society welcomes the opportunity to comment on the proposal of the revised ETS Directive. Please find attached our analysis on ETS revenues use (Art. 10(3) of the Directive) - current practice in the Czech Republic. The main outcomes of the analysis are: - FBS welcomes the revision draft of the ETS Directive, which suggests that 100 % of ETS revenues should be used for environmental measures. We believe that this measure could be more efficient if Member States were to provide information more transparently and publicly on how they spend these revenues. - FBS suggests that it is necessary the revised ETS Directive introduces more specific rules on transparency of ETS revenues use, which would enable the public as well as the European Commission to verify that all the requirements of the ETS Directive have been met. - More information should be available about the specifics of projects supported by Member States. For this purpose, FBS also suggests Member States publishing reports regularly to the European Commission on how they manage ETS revenues. - ETS revenues should be handled separately from the state budget, so that they cannot be diluted and only retrospectively (formally) allocated to any costs eligible under Art. 10(3) of the ETS Directive. - More attention should be paid to the effects of the spending of ETS revenues – especially the motivational effect of the expenditure, but also the overall contribution to the goals of the ETS system. The use of ETS revenues should be strictly assessed in the light of EEAG and made compliant with its requirements for state aid, including its incentivising effect. Frank Bold Society also suggests that the revised ETS Directive and the Industrial Emissions Directive (IED) must translate the European and international climate targets into tangible legal measures. To set effective GHG performance standards and mandatory energy efficiency requirements, the exclusion rule in Art. 26 of the ETS Directive should be deleted, as well as the corresponding provision of Art. 9 of the IED. For further details, we refer to the submission to this consultation made by ClientEarth.
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Meeting with Thierry Breton (Commissioner) and

8 Nov 2021 · Sustainable Corporate Governance

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and WWF European Policy Programme and

28 Oct 2021 · Sustainable corporate governance initiative

Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen), Renaud Savignat (Cabinet of Commissioner Jutta Urpilainen) and

17 Sept 2021 · upcoming proposal on sustainable corporate governance

Meeting with Simona Constantin (Cabinet of Vice-President Věra Jourová) and Global Witness

27 Jul 2021 · Sustainable Corporate Governance

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager) and Global Witness and

7 Jul 2021 · Sustainable corporate governance

Meeting with Mikuláš Peksa (Member of the European Parliament)

4 Feb 2021 · EU Non-financial reporting directive

Meeting with Axel Voss (Member of the European Parliament)

14 Oct 2020 · Corporate Transparency

Response to Sustainable corporate governance

6 Oct 2020

Frank Bold is a public interest law organisation leading the Purpose of the Corporate project and coordinating the Alliance for Corporate Transparency. Addressing the compound problem of short-termism and undue focus on maximisation of shareholder value requires the implementation of a comprehensive set of interconnected reforms in the area of company law, corporate reporting and finance. With regard to matters covered by the Inception Impact Assessment, we would like to make the following recommendations: 1. Corporate due diligence duty is essential to ensure that corporations meet their responsibility to respect human rights as outlined in international standards. The purpose of this responsibility is to help to protect adversely affected people. Therefore, in order to have the intended effect, the regulation of due diligence must ensure that people who have suffered harm have access to remedy backed by judicial mechanisms. This enforcement option is important for the effectiveness of the duty as such, because corporate governance does not include any accountability mechanism that could support it. 2. Requiring directors to simply take into account stakeholders' interests will not change the current state of affairs in any significant way. The Commission should therefore focus more specifically on the Board’s obligation to develop and oversee the implementation of a strategy and targets addressing sustainability risks and impacts. This obligation should explicitly include a requirement to ensure that sufficient financing is made available to implement the strategy. 3. To enable accountability, directors should be responsible for producing an annual progress report, as part of the company’s non-financial reporting. Furthermore, the determination of the strategy should correspond with a) the significant impacts identified in line with companies’ due diligence obligations and b) the determination of material issues and relevant targets as per the non-financial reporting legislation. Such a coherent approach would minimise any additional costs for the company. 4. The obligation should be supported by appropriate accountability mechanisms. Firstly, it needs to be connected to directors’ duty of care in order to enable shareholders to enforce it on behalf of the company. Secondly, public authorities should be empowered to bring proceedings against directors where non-implementation has caused serious harm to third parties or unlawful harm to the environment. 5. The Commission should consider options to regulate stock-based executive remuneration in order to remove incentives to focus on short-term strategies to maximise share price such as share buy backs and paying excessive dividends at the expense of the company’s economic health and ability to invest across all types of capitals needed for its success and sustainability. 6. Finally, stakeholders’ interests can be furthered directly in corporate governance by providing for employees’ representation in the board of directors. Workers’ interests are more closely aligned with the long-term interests; therefore their representation in corporate governance provides safeguards against excessive short-termism. 7. In consideration of economic impact, the Commission needs to take into account costs that are currently externalised to stakeholders, as well as costs that will materialise in the long-term in connection to the climate breakdown. The potential negative impact of the reform on short-term returns to shareholders, as result of redirection of company’s investments from shareholder payouts, should be considered against the impact on the company's investment capabilities. The analysis of economic impact should consider the disadvantages currently facing companies that have already adopted ambitious sustainability targets. 8.The Commission should consider the lack of evidence on positive effects of non-binding initiatives in the field of corporate governance implemented to date.
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis) and Transport and Environment (European Federation for Transport and Environment) and

15 Sept 2020 · Sustainable finance

Response to EU rules on industrial emissions - revision

20 Apr 2020

Frank Bold Society, z.s., welcomes the opportunity to comment on the roadmap for the planned revision of EU rules on industrial emissions. Please find attached our feedback.
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Response to Commission Implementing Regulation on the Modernisation Fund

13 Mar 2020

Frank Bold Society welcomes the opportunity to give feedback on EU’s on Modernization Fund regulation proposal. We would like to express our concerns on the following matters. The major question mark is still how will the Member States initially select investments to propose to the EIB and the investment committee? This issue is not resolved within the regulation proposal. In our opinion, the lack of clear selection process and criteria on the Member State level may result in: politicising of the selection process of the projects selection, selection of the projects that not necessarily are most beneficial in terms of achieving net zero GHG emissions. Favoritism of big-scale projects at the expense of small-scale projects and just transition related projects, lack of transparency of the process. Additionally, the proposal is ambiguous about the number of elements and rules remaining to be decided and operationalized by the Commission in its implementing act(s), or by the Member States, as the Modernisation Fund will operate under their responsibility. Furthermore, the draft contains no information about how the monetization of allowances will take place in practice. The Directive provides information that the EIB will be responsible for the monetization process and the management of the Fund but information about its exact mandate is not clear. Additionally, we propose to add provisions regulating the publication of documents in order to increase transparency of the selection process: In the Article 6 (Confirmation of priority investments) we propose to add following point 11: "The decisions on confirmation of the proposal as a priority investment will be published on a special website no later than two weeks after approval." In the Article 7 (Recommendations on non-priority investments) we propose to add following point 11: "The decisions on recommendation on non-priority investment will be published on a special website no later than two weeks after approval." Finally, the regulation proposal does not contain information about constraints on the investment schedule adopted in the implementing act for investments in general or adopted by the EIB or investment committee for specific investments.
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Response to EU implementation of the Aarhus Convention in the area of access to justice in environmental matters

4 Jun 2018

Amendment of the Aarhus Regulation (AR) is the most suitable means for the EU legislature to bring EU in compliance with its obligations under article 9(3) of the Aarhus Convention. The ACCC found EU to be in violation of the Convention by failing to provide members of the public with access to the EU courts to challenge acts and omissions of the EU bodies relating to the environment. Findings of the ACCC recommended to amend the AR or adopt new legislation in the absence of a change in jurisprudence of the CJEU. The lack of agreement on the findings at the last Meeting of the Parties was due to the EU Commission’s block of endorsement of the ACCC’s decision. However, some of the other Parties strongly opposed to the EU’s argumentation. The decision was therefore postponed. By now, the EU Member States have also realized that the EU cannot exempt itself from international law obligations, as demonstrated by the intent of the Council to make an official request based on Article 241 TFEU to the Commission asking to adopt a legislative proposal. The European Parliament and EESC have also called upon the Commission to comply with the findings of the ACCC and to revise the AR. Rather than being “already complete” as stated in the Roadmap, the EU system of remedies suffers from considerable shortcomings. The preliminary reference system under Article 267 TFEU does not meet the requirements of Article 9(3) of the Convention. Over the last years, the CJEU has further consolidated its case law clarifying that members of the public have no standing under Article 263 TFEU to challenge acts and omissions of EU institutions that are not addressed directly to them. The AR is the only remaining avenue for the public but it remains unduly restrictive in its current form. Other areas of EU law do guarantee access to the EU courts with considerably less stringent conditions. In particular areas (anti-dumping, competition, state aids) the Court has treated the rules for standing in a more generous way. In competition law, cases such as Case 11/82 Piraiki – Patraiki or C-152/88 Sofrimport Sarl signify that business undertakings have legal standing without having to prove such a level of affectedness as NGOs with respect to acts relating to the environment. Since the adoption of the AR in 2006, members of the public have attempted to request the internal review of a range of acts of the EU institutions. However, only 7 out of 35 requests have been declared admissible. Almost all of these requests were denied on the basis of the requirement that an ‘administrative act’ must be of “individual scope” and “have legally binding and external effects”. The ACCC found that application of these requirements, as well as other aspects of the AR, fail to comply with the Convention. Although on the basis of the first instance judgment of the General Court in Case T‑338/08, many believed that the case law of the Court will change to allow broader standing based on the AR, the judgment of the Court of Justice in Joined Cases C‑404/12 P and C‑405/12 P cooled down the expectation, returning to the traditional, restrictive construction of access to justice in EU law. The Court refuses the standards of NGOs standing in environmental cases, which it itself requires the Member states courts to apply (C‑240/09 Slovak Brown Bear and subsequent case law). The situation is therefore clear: (1) The EU is a party to the Aarhus Convention in its own right; it therefore constitutes an integral part of the EU legal order. (2) The EU is in non-compliance with the Convention and therefore violates international law and primary EU law. (3) Based on one of the fundamental principles of the international legal order (article 27 of the Vienna Convention), the EU cannot avoid performing its obligations by invoking its internal law. (4) The only option open to the Commission to remedy this violation is to propose an amendment of the legislation, most naturally of the AR.
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Meeting with Věra Jourová (Commissioner) and

16 Feb 2016 · Corporate social responsibility