The AMF publishes an educational report on listed companies' sustainability reporting

In its supervisory work, the AMF relied in particular on the European supervisory priorities defined by the European Securities and Markets Authority (ESMA). The report is based on the comments sent by the AMF to issuers whose NFS was examined in 2023 or 2024.

The AMF highlights the main areas for attention regarding the disclosures to be made on environmental, social and governance (ESG) issues, which remain relevant in the light of the Corporate Sustainability Reporting Directive (CSRD), without prejudice to any European decisions on this text. The report therefore includes numerous examples of reporting and regulatory focuses on this text.

This report covers the following reporting areas:

• Description of the business model;
• Identification of impacts, risks and opportunities (materiality assessment);
• Presentation of targets and performance indicators;
• Presentation of policies and actions;
• Description of governance associated with sustainability issues;
• Reporting under Article 8 of the Taxonomy Regulation.

The AMF’s comments primarily relate to the inclusion of information necessary for a proper understanding of the undertaking’s sustainability issues and of how these issues are managed, which is a key point for investors. They specifically focus on information on the scope of reporting and on the methodology used to analyse and calculate the data. The comments also reflect the importance of ensuring the overall consistency of disclosures, including consistency between financial and sustainability information. A significant proportion of the comments also relate to climate reporting, in line with ESMA’s previous European supervisory priorities.

These comments on the NFS remain relevant in the context of the CSRD. The report highlights the significant differences in the level of requirements between the NFS and the sustainability statement prepared in application of the new directive. The CSRD requires a more in-depth analysis of the undertaking’s sustainability issues, and a significantly greater amount of data to be provided.

With regard to taxonomy reporting, the comments addressed to undertakings mainly cover how indicators should be presented in the templates, and the publication of the contextual information needed to understand the methodology used to analyse and calculate the indicators. The AMF reiterates the importance of conducting a comprehensive assessment of the undertaking’s activities in relation to all the environmental objectives of the taxonomy.

In order to help undertakings make the transition to the new regulatory framework, the AMF highlights in this report a number of examples of good practice that can help to prepare the sustainability statement (CSRD and Taxonomy reporting). Acknowledging the learning curve that all market participants have to overcome in the first years of implementing the CSRD, the AMF invites large companies to focus their efforts on the materiality assessment, the structure and scope of the sustainability statement and on the taxonomy disclosures, in line with ESMA’s 2024 priorities.

About the AMF
The AMF is an independent public authority responsible for ensuring that savings invested in financial products are protected and that investors are provided with adequate information. The AMF also supervises the orderly operations of markets. Visit our website https://www.amf-france.org/en