PostEurop would like to contribute to the ongoing process of drafting sector specific standards as foreseen by the Corporate Sustainability Reporting Directive (CSRD) of 14 December 2022 and subsequent European sustainability reporting standards (ESRS) Delegated Regulation of 31 July 2023. Sector-specific standards and sustainability reporting are vital. They help achieve Paris-aligned objectives, mitigate climate change, manage the workforce (since logistics and transport services are people-centric), ensure good governance, and reduce air pollution.
Rationale
PostEurop recommends that EFRAG and the European Commission prioritize assessing disclosures from the initial and subsequent reporting cycles of sector-agnostic European Sustainability Reporting Standards (ESRS). This assessment will help identify key sustainability matters in the road transport sector and create meaningful, concise sector-specific reporting standards.
PostEurop strongly advocates for close collaboration with sector representatives to establish practical and feasible reporting obligations. While postponing sector-specific standards is positive, companies need extended timelines to ensure comprehensive adaptation. The diverse roles and implications of sector standards necessitate a thorough and nuanced implementation approach.
Delaying the Commission’s adoption of these standards does not reduce reporting burdens; it merely postpones them. Currently, existing standards require approximately 84 disclosure requirements, resulting in over 1100 data points. This significant effort necessitates evaluating the need for further standards. PostEurop urges the Commission to reduce reporting burdens and provide additional time for companies to implement sector-specific standards. PostEurop welcomes the fact that in the EFRAG questionnaire on Sustainability matters for Road transport, the postal activities have been identified as a sub-sector to better take into account their specificities.
We call on the Commission to consider adopting guidelines rather than introducing more disclosure requirements.
Developing Sector-Specific Standards /Guidelines Measurement System
It’s crucial to recognize the distinct role sector-specific standards play within ESRS, differing from frameworks like ISSB or SASB. While SASB/ISSB focus only on “financial materiality” and ignore double materiality, sector-specific standards address the impact materiality dimension.
In contrast, CSRD/ESRS integrates double materiality, differing from SASB/ISSB paradigms. Therefore, sector-specific standards should align with broader, sector-agnostic standards, adhering to double materiality rather than introducing new disclosure requirements. These standards should be subject to materiality or limited in disclosure requirements to ensure they are appropriate, meaningful, and useful for transport operators and for all relevant stakeholders incl. investors, shareholders and NGOs.
GHG Emissions Reporting
Any standard for reporting greenhouse gas (GHG) emissions from transport should align with existing International and European calculation standards and methodologies. Notably, EN ISO 14083, EN 17837 and the forthcoming CountEmissionsEU, which share the same underlying principles and complement each other. The EN ISO 14083 combined with the EN 17837 are particularly relevant as they consider the specificities of the freight and postal sectors, which have already been identified as sub-sectors in the EFRAG questionnaire on Sustainability Matters for Road Transport.
Business-Sensitive Information
Companies should avoid using granular business-sensitive information for CapEx and transition plans that could reveal business models (e.g., on a country level) to prevent competitive disadvantages.
CONCLUSION
Companies should be given sufficient time to prepare for new reporting requirements. Postponing the adoption date of sector-specific ESRS will allow companies to focus on implementing the first set of ESRS adopted on July 31, 2023. This also ensures that EFRAG has sufficient time to develop high-quality sector-specific ESRS and limit reporting requirements.
PostEurop calls for prioritizing an assessment of ESRS disclosures and collaborating with sector representatives to establish feasible reporting obligations. Delaying adoption only postpones reporting burdens, but the industry needs additional time to adapt to new disclosure requirements. Therefore, we recommend at least one year between adoption and first-time reporting.
In order to create comparability, sector-specific standards in road transport should align with existing global and European standards for GHG emissions reporting taking into account the specificities of the postal activities. In general, full alignment with sector related EU legislation is urged to develop applicable and meaningful standards. Companies should avoid disclosing business-sensitive information to prevent exposing themselves to competitive disadvantages.
Download here the Position Paper