July 07, 2023

European sustainability reporting standards

Carbon Gap's comments on the ESRS
Carbon Gap EU policy consultation feedback
Carbon Gap’s response to the ESRS
Feedback reference: F3429990

The European Sustainability Reporting Standards (ESRS) E1 represent many improvements to emissions reporting and the transparency of environmental information. The simple fact of disaggregating emissions from carbon credits already changes a lot of the attractivity of widespread unsubstantiated net zero claims at organisation level. The introduction of GHG intensity reporting is also something Carbon Gap welcomes as it would facilitate innovative financing mechanisms for carbon dioxide removal (CDR), such as those discussed in our Bridging the Ambition Gap report. However, the proposed Carbon Removal Certification Framework could be more explicitly integrated in GHG removals and credits reporting requirements. The EU is developing methodologies to verify the quality and integrity of carbon removals reliably. It would be a missed opportunity not to take advantage of this work for reporting on carbon credits in the same way it is done for GHG removals within undertakings value chains. Lastly, the reporting requirements for public claims of GHG neutrality should be more specific. Instead of remaining optional, net zero and emission reduction targets should be required when making such claims. Furthermore, there should be requirements to report the year-on-year evolution of emissions reductions and the progress toward the targets mentioned above. From this information, civil society and authorities will be able to determine whether GHG neutrality claims are legitimate and whether they impede or reduce the achievement of an undertakings emissions reductions targets.