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Umweltbundesamt GmbH - Environment Agency Austria

EAA

The Environment Agency Austria (EAA) is the expert authority of the federal government in Austria for environmental protection and environmental control.

Lobbying Activity

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

26 Mar 2025

1) The amendments included in this proposal are considered to be positive in those areas where simplifications of the reporting templates are proposed. However, it has to be ensured that the material information is retained and ambiguities are eliminated. 2) With regard to the generic DNSH criteria for PPC (Appendix C), it is noted that of the two options available for selection, option 2 is clearly preferred. 3) A de-minimis threshold may in principle provide relief and therefore seem sensible. However, the proposed financial materiality threshold of 10% means that companies do not have to report their taxonomy-related KPIs if the cumulative value of the activities is below 10% of the denominators of the KPIs. This threshold is considered critically. It is recommended to lower this threshold to 5% and also to introduce an absolute materiality threshold value for turnover, the balance sheet total and CapEx. The reason for this is that 10% can already amount to billions in turnover for large companies, and these economic activities may indeed have a significant environmental impact. It is therefore important for investors, financial institutions, decision-makers of companies themselves and supervisory authorities to know these figures. 4) Eliminating the asymmetry between numerator and denominator in the GAR calculation is essential, but is not adequately addressed in the current proposal. 5) In order to achieve a significant reduction in the burden of taxonomy-related disclosure obligations, it is recommended that OpEx KPIs should only be reported on a voluntary basis, except for OpEx for research & development. This should continue to be mandatory, as this serves as a key indicator for assessing the future orientation of a company. However, there should be clear instructions for this in order to minimise the calculation effort. 6) The possibility to report partial taxonomy alignment (separately for the SC criteria and the individual DNSH criteria) is welcome in principle. However, care should be taken in the specific design to ensure that this does not create additional complexity, which would contradict the basic idea of simplification. Furthermore, this option should also be available to all other companies. 7) By increasing the thresholds for companies subject to reporting requirements from the current 250 employees to 1000 employees, the scope of companies subject to reporting requirements would be drastically reduced (by around 80% according to the Commission). This would have a number of negative consequences: a) The existing data gap for financial companies, which are dependent on data from the real economy, would remain and would not be resolved. In addition, the quality of reporting is likely to stagnate or decline, as many companies have tried to implement the reporting obligations very precisely in anticipation of future obligations. However, this incentive will disappear with the cancellation of a possible future reasonable assurance. b) Investors, banks and supervisory authorities will therefore hardly have any reliable data available in the future to measure and monitor the alignment of portfolios with climate and environmental targets. Financial institutions would also lack the data to fulfil their own reporting obligations and risk management requirements (e.g. CRR). 8) By introducing different scopes for CSRD reporting and taxonomy reporting, this proposal does not contribute to harmonisation, but rather creates new uncertainties and inconsistencies. In addition, the availability of data for investors, financial institutions, customers, politicians and the administration is reduced; 9) Recommendation: Introduce one single threshold of 500 employees: The scope of the companies affected by the reporting obligations under the Taxonomy Regulation and CSRD should be harmonised by setting a single threshold of 500 employees for both regulations, above which reporting is required.
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Response to European Sustainability Reporting Standards

7 Jul 2023

In general, we welcome that the Commission has decided to include the entirety of ESRS proposed by EFRAG in the delegated act. A first quick cross-check shows that no major disclosure requirements (DR) have been excluded from the standards by the Commission, although some DRs were changed in their content and therefore their meaningfulness. We see critically the general modifications the Commission is proposing in terms of: - dropping the mandatory reporting requirement for all ESRS excluding ESRS 2 by extending the materiality assessment to all standards, including the standard on climate (ESRS E1) and the indicators linked to other EU legislations (SFDR, Pillar 3 banking regulation) - considerably expanding the phase-ins of certain requirements - making certain disclosures voluntary, especially regarding the standard on biodiversity (ESRS E4) and the fact, that it is not mandatory anymore to report on the reasons on why a sustainability topic has been deemed not material Detailed comments on those points are provided in the attached document.
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Meeting with Alexander Bernhuber (Member of the European Parliament, Shadow rapporteur) and Wirtschaftskammer Österreich and

24 Oct 2022 · Sustainable use of Pesticides - Stakeholder Dialog

Meeting with Delara Burkhardt (Member of the European Parliament)

30 May 2022 · Circular Economy

Meeting with Janusz Wojciechowski (Commissioner) and Helmholtz-Gemeinschaft Deutscher Forschungszentren e.V. and Humboldt-Universität zu Berlin

17 Jun 2020 · How science can help the next CAP be greener and more sustainable.

Meeting with Virginijus Sinkevičius (Commissioner) and

15 Jun 2020 · To discuss how the scientific support can be used in streamlining the Common Agriculture Policy with the European Green Deal, as well as with the targets of Biodiversity Strategy.

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski) and Helmholtz-Gemeinschaft Deutscher Forschungszentren e.V. and

15 May 2020 · To discuss how science and scientists can help improve the CAP, restore public trust, the EU’s Green Deal, Farm to Fork Strategy and their implications for the CAP reform, how to best restore markets and economy after COVID-19 crisis.