We are generally in favour of standardised, uniform and database-based reporting which is readable for both humans and machines. We also welcome the associated aims, especially that of creating comparability across businesses. However, we consider it vitally important that ESAP introduces no additional information requirements compared to the status quo. Also, the technical implementation of the ESAP must not restrict the legal possibilities provided for in current legislation: We therefore advocate, that in the further legislative process and in the development of the technical implementation standards, care must be taken to ensure that the additional efforts are as low as possible.
