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Value Balancing Alliance e.V.

VBA

The value balancing alliance e.V.

Lobbying Activity

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

27 Jan 2022 · CSRD and discussion about Munich Security Conference on 18 Feb 2022 where Commissioner McGuinness will speak.

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

27 Jan 2022 · Sustainable finance & Corporate Reporting

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and Falk Beratung GmbH

19 Jul 2021 · Sustainable Finance and CSRD framework

Response to Revision of Non-Financial Reporting Directive

14 Jul 2021

We fundamentally endorse the European Commission's proposal for a new Corporate Sustainability Reporting Directive (CSRD). Our enclosed feedback document is based on the Value Balancing Alliance's (VBA) experience of developing a global and standardized impact measurement and valuation methodology and on the perspective of the real economy which the VBA members represent. For completeness, we refer to our previous responses to the public consultation on the revision of the NFRD in 2020 and the consultation on the Draft Delegated Act Article 8 of the Taxonomy Regulation in 2021. 1.1.1 Global standards for market transparency: The European Commission should align its regulatory strategy with global developments in sustainability reporting currently underway outside the European Union, especially the processes towards the IFRS ISSB, the policy-making initiatives at the G7, G20, as well as at IOSCO and national regulatory agencies such as the US SEC. 1.1.2 Double Materiality and impact valuation: We welcome the European Commission's reference to the Transparent Project led by the Value Balancing Alliance in collaboration with the Capitals Coalition and the WBCSD.1 The EU's disclosure framework should ensure comparability based on enterprise value and impact valuation. The VBA endorses the double materiality principle (Figure 1): the impact of business on and its value to society and the environment on the one hand ("Inside-out"), and, on the other hand, the environmental and social impacts on enterprise value ("Outside-In"). 1.1.3 Independent and evidence-based standard-setting: Standard-setting should be based on due process and governance that meets the general standards of independence, expertise, transparency, public consultation, oversight, and effectiveness currently upheld by organizations such as IASB and SASB (now the Value Reporting Foundation). We fundamentally support the preparatory work of the EFRAG Taskforce and their alignment and cooperation with key standard-setting organizations. Please refer to the enclosed document as VBA Feedback on CSRD (July 2021). For completeness, we also refer to our consultation response to the NFRD review in June 2020 and the recent consultation on Art. 8 of the Draft Delegated Act of the Taxonomy Regulation in 2021.
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Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

14 Jul 2021 · Corporate Sustainability Reporting Directive (CSRD)

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

14 Jul 2021 · CSRD

Meeting with Marius Vascega (Cabinet of Commissioner Virginijus Sinkevičius)

11 Jan 2021 · Presentation of VBA work, focusing on the project TRANSPARENT but also the work in the Platform Sustainable Finance.