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2023.10.06
Criticism expressed in consultation responses to the Ministry of Justice
Swetic sees that the EU Commission's CSRD directive will play a crucial role in the Union's green transition. Therefore, carefully balanced implementation of the directive in Swedish legislation is of utmost importance for the continued competitiveness of Swedish companies. A central part of the directive is the requirement for independent review and verification of sustainability reports. However, Swetic criticizes the inquiry's proposal not to open up the possibility for independent accredited quality reviewers to carry out the review of sustainability reports, even though the CSRD directive allows this. We believe that the proposal limits companies' flexibility and creates a risk of a skills shortage when more companies have to comply with the requirements for sustainability reporting and review.
In our consultation statement, we primarily highlight three important points:
1. Distorted competition: Not opening up the possibility of having more actors carry out the review of sustainability reports from the start is unethical from a competitive point of view. The advantage that authorized audit firms would gain will be almost impossible for other actors to catch up with. In addition, the cost will likely be significantly higher for commissioning companies if only a few actors are allowed to validate the content.
2. Existing accreditation system meets the requirements of CSRD. The investigation claims that existing accreditation systems cannot be applied cost-effectively and quickly to meet the requirements of the CSRD. These are assumptions that lack factual basis. The accreditation system meets the needs of the parties and ensures proper governance and the ability of accredited companies to carry out the audits while ensuring independence. Existing standards such as the international ISAE 3000 are open to everyone to apply, thus also for financial auditors
3. International practice: Several European countries, including Norway, Denmark, Italy and Austria, are likely to allow independent quality reviewers under the CSRD directive. In France, this is already clear.
Excluding more actors from the review of sustainability reports will therefore likely result in a skills shortage and prevent Swedish companies from meeting the requirements set to create a sustainable and climate-neutral business sector.
