CONTEXT
PostEurop welcomes the European Commission initiative to review the EU ESRS and to update and simplify the criteria. This position is based on the practical experience of PostEurop members in the implementation of sustainability reporting and we would like to underline the following issues:
Double Materiality Assessment (ESRS 1 Paras. 22-55)
PostEurop doesn’t consider that it is relevant to include remediation actions for current negative impacts in the DMA; it would be more useful to remove this point for the sake of simplification or, at the very least, to clarify it. The terms of the overall consistency of the methodology, treating current negative impacts differently from other impacts, risks, and opportunities—which are still reported on a gross basis—tends to create complexity.
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