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Omnibus - Share your thoughts

Hello and thank you for your interest in our work on the Omnibus. Before answering the following form, please note that the answers will only be used by my team and will not be shared publicly. You do not have to answer all the questions to send the form. Please also feel free to watch the replay of my LinkedIn Live before formulating your answers. Please keep your comments within a reasonable word limit - Deadline 4th of June.

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CSRD

What are your thoughts on dividing the reporting thresholds into three stages, as proposed by the European Central Bank, with a VSME stage (up to 500 employees), a stage with lightened ESRS and a simplified audit (from 500 to 1000 employees) and full ESRS (for over 1000 employees)?

Can potential sector-specific ESRS help to simplify the analysis of dual materiality and reduce the number of datapoints?

Are the VSME standards sufficient to enable information to be aligned with the ESRS and their dual-materiality? In case of lack of information from the VSME standards, are you using proxies?

Could a move to a' consistency check' audit for companies between 500 and 1 000 employees or for the dual materiality analysis for the first years of reporting be a useful learning phase?

In light of the latest developments in the United States and China, are you encountering conflicting regulatory requirements when it comes to reporting? If so, how can we avoid this pitfall while maintaining our sovereignty over ESG data?

What should be the priorities for EFRAG's review of the ESRS?

CSDDD

Could the withdrawal of a European civil liability regime (art29 of the CSDDD) fragment your activities on the EU market?

Does the European Commission's ‘tier 1’ approach reduce the administrative burden for companies?

Is the SME shield and the derogation proposed by the Commission in the Omnibus a good compromise?

Do you think it makes sense to move from an annual assessment to one every 5 years?

Today there is an obligation of means, not of results, regarding transition plans. Do you think the Commission's new approach on this point in the Omnibus is relevant? How can the CSRD and CSDDD approaches be reconciled?

Taxonomy

Do you think the European Commission's proposal for a partial and voluntary taxonomy for companies under €450m is relevant?
Could it hinder the redirection of investment towards sustainable products?

Other

Any other comments?