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Sustainable finance

ESG regulation - banks and insurers offer guidance on data requirements in English and French

11.12.2024Position paper
Adrian Schwantes
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  • Joint ESG data catalogue for large companies by the Bankenverband (BdB), German Insurance Association (GDV) and German Public Banks (VÖB)
  • Supported by Verband Deutscher Treasurer (VDT) and Bundesverband der Deutschen Industrie (BDI)

The associations of Germany’s private and public banks (Association of German Banks & VÖB) as well as of the German insurance industry (GDV) have jointly developed an ESG data catalogue for large corporates. This catalogue outlines the typical data requirements of banks and insurers in relation to large companies subject to sustainability reporting requirements.

The ESG data catalogue is designed to assist insurers and banks in both achieving their own sustainability goals and complying with legal and regulatory sustainability requirements. Accoringly, the ESG data catalogue covers general information on the sustainability of companies as well as data points in the areas of environment, social responsibility, and corporate governance. The catalogue contains only 20 sets of questions to minimise the effort of companies when responding. The catalogue is based on the following frameworks (as of April 2024):

  • The Corporate Sustainability Reporting Directive (CSRD) amending the Accounting Directive and its corresponding European Sustainability Reporting Standards (ESRS);
  • The EU Taxonomy Regulation;
  • The EU Disclosure Regulation;
  • The BaFin guidance on dealing with sustainability risks;
  • The draft guidelines of the European Banking Authority (EBA) on the management of ESG risks.

The ESG data catalogue’s target audience are companies required to publish sustainability reports under the CSRD. Therefore, the ESG data catalogue is aligned as closely as possible with the rules and methods of the CSRD and ESRS. All information relates, uncles otherwise indicated, to the most recently concluded financial year. Small and medium-sized enterprises are not the immediate target audience of this ESG data catalogue. Individual circumstances of specific sectors and the materiality assessment of the CSRD are taken into account by providing a “not relevant” option for certain data points.

This ESG data catalogue does not represent a unified or comprehensive set of questions and is not binding. Rather, it serves as a guide to illustrate the typical data requirements related to sustainability for large companies. The catalogue does not contain sector- or transaction-specific data requests. Banks and insurance companies are free to collect additional ESG-relevant data if necessary. 

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Adrian Schwantes