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FSR - danske revisorer

FSR

FSR – danske revisorer er en organisation inden for revision, regnskab, skat og virksomhedsøkonomi, og repræsenterer revisorbranchen i Danmark.

Lobbying Activity

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

13 Jun 2025 · Debate on the omnibus

Meeting with Stine Bosse (Member of the European Parliament, Shadow rapporteur for opinion) and The Danish Chamber of Commerce

30 Apr 2025 · Omnibus I proposal

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and The Danish Chamber of Commerce

30 Apr 2025 · Sustainability omnibus

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

5 Mar 2025 · Omnibus

Meeting with Niels Flemming Hansen (Member of the European Parliament)

5 Mar 2025 · Omnibus

Meeting with Christel Schaldemose (Member of the European Parliament)

5 Mar 2025 · Omnibus package

Response to European Sustainability Reporting Standards

7 Jul 2023

FSR Danish Auditors is Denmark's trade organisation of auditing, accounting, tax and corporate finance. With more than 500 member firms and 4,500 individual members, we are the voice of the Danish audit profession. Danish audit firms has a combined annual revenue of app. 3.1 billion in 2021. We are thankful of the opportunity to provide a few key comments on the (EC) draft Delegated Act (DA) on the first set of ESRS. Since the establishment of the Project Task Force for Non-Financial Reporting Standards by EFRAG in 2020 on request of the Commission, we have contributed financially and in kind to the work by EFRAG to put forward the later requested technical advice on mandatory European standards for sustainability reporting. On this background we are now pleased to see the Commission issuing the full set of 12 ESRS developed by EFRAG, while substantially retaining the content of the standards. In our view, improvements can still be made to enhance clear and easy to use standards. The 12 ESRS bear the mark of being developed over very short time, given only few weeks for public consultation, or time for assignment to professionals familiar with corporate reporting for an intensive review of terms, definitions, and basic reporting principles. Therefore, we call for an intensive review by reporting professionals of all 12 ESRS before the adoption of the DA. We commend the Commission for extending the list of phased-in disclosures making more options for smaller undertakings to prepare properly for the implementation of ESRS over 2-3 years. We are convinced that this will have a positive effect on data quality and will lower the risk of incomplete sustainability statements in the first years. We appreciate the Commissions consideration for undertakings not having users (or only having few users) requesting immaterial information used only for statistical purposes or likewise, i.e. information that is not necessary to understand the impacts of activities on sustainability matters, or the risks and opportunities arising from such impacts. In general, we favour the principle of materiality for corporate reporting. Financial reporting has over many years matured and improved by e.g. the IASB providing more guidance on materiality in order to not reducing the understandability of the reporting by obscuring material information with immaterial information. For some parts of the management report, the legal requirements are for obvious reasons of mandatory nature, such as information on corporate governance. In our view, the exercise of balancing between materiality assessments and requirements of mandatory nature is something undertakings and auditors are well familiar with in respect of corporate reporting. We understand the concerns of financial users and benchmark administrators not being sufficiently supplied through corporate reporting with externally validated information needed for other regulation that does not allow thresholds for materiality. These reasonable concerns could be met by reconsidering the benefits of not allowing materiality thresholds in other regulation depending on disclosures in corporate reporting. Our main concern is that the provisions on materiality assessment are not sufficiently clear to meet the precondition for third party assurance being that the undertaking establishes sufficient documentation for disclosures deemed not material for inclusion in the sustainability statements. A materiality assessment process generally entails the collection and/or recording of more data than disclosed, as it is the responsibility of the undertaking, not the assurance provider, to ensure compliance with the ESRS. We recommend the Commission emphasising the relevance of data collected or recorded for materiality assessments for all disclosure requirements, regardless of what information the undertaking would conclude material for disclosure. Please find our full feedback in the attached file.
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Response to Initiative on EU taxonomy - environmental objective

2 May 2023

FSR Danish Auditors is Denmark's trade organisation of auditing, accounting, tax and corporate finance. With more than 500 member firms and 4,500 individual members, we are the voice of the Danish audit profession. Danish audit firms has a combined annual revenue of app. 3.1 billion in 2021. FSR Danish Auditors would like to congratulate the Commission and the Platform on Sustainable Finance for the work done to produce a draft delegated act on the technical screening criteria for four environmental objectives in the Taxonomy Regulation1 and revisions of existing delegated acts to same regulation. We fully support the objective of transforming Europe into the first climate-neutral continent in the world by 2050, in which the EU Taxonomy is key in defining sustainable activities as a baseline for change of the economical ecosystem. In this respect relevant and reliable sustainability information is crucial and a fundamental precondition for the success of sustainable finance. On this basis, we find the feedback period of four weeks very short. Hoping that this will not diminish the amount or quality of the comments from organizations working with the EU Taxonomy in practice, we strongly encourage the Commission to ensure that sufficient time is spent to assess the comments received and make the necessary changes to ensure a high quality of the final delegated acts. The new draft delegated act covers the following four environmental objectives: sustainable use and protection of water and marine resources, transition to a circular economy, pollution prevention and control, and protection and restoration of biodiversity and ecosystems. A complicating factor for assessing substantial contribution criteria for nature-related objectives are the lack of equivalents to the simple metrics as those used for assessing the climate-related objectives such as global temperature or greenhouse gas emissions. Because the nature and extent of the nature-related objectives is differing from climate-related objectives, we believe guidance and interpretations is even more needed for the remaining four environmental objectives. We suggest that guidance and interpretations are further developed both on the technical screening criteria and the use of the reporting templates, but also on how to demonstrate compliance with minimum safeguards. We have elected to focus our comments on: - The proposed application date. - The absence of a materiality principle in the Disclosures Delegated Act. - The usefulness of columns for DNSH criteria and Minimum Safeguards in the templates for non-financial undertakings and of the options to disclose Yes or No in these columns when Yes seems to be the only possible option for taxonomy-aligned activities. - The need to clarify how to present economic activities contributing substantially to multiple environmental objectives, including the total of taxonomy-eligible but not taxonomy-aligned activities. - The need to clarify good conditions as one of the technical screening criteria for activity BIO 1.1 Conservation, including restoration, of habitats, ecosystems and species. For full feedback, please see attached document.
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Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and The Danish Chamber of Commerce

13 Dec 2022 · reporting standards under the CSRD