In response to the SEC’s consultation on climate-related disclosures proposed rule, Afep highlighted the following points:
Equivalence should be granted to European (ESRS) and international (IFRS Sustainability Standards) standards under development.
Companies using the GHG Protocol should be able to continue.
Flexibility should be given to companies to choose to disclose GHG intensity per unit of production or per unit of total revenue.
Align the implementation timeline of the proposed rule as well as the level of assurance required with the EU CSRD.
Base the requirement to disclose financial metrics on the materiality concept generally used in the establishment of financial statements and not on a quantitative threshold.
Publish these financial metrics in a separate report and note in a note to the financial statements.