Comment letter on the Draft Delegated Regulation on revised European Sustainability Reporting Standards (ESRS) 

Government of Japan issued a comment letter dated May 13, 2026, regarding the Draft Delegated Regulation on revised European Sustainability Reporting Standards (ESRS), which was published on May　6, 2026, by the European Commission (EC).

In this comment letter, we make the following proposals regarding N-ESRS (ESRS for non-EU groups):

• To allow non-EU companies to use the sustainability report complying with IFRS Sustainability Disclosure Standards and provide N-ESRS-specific disclosures on top, when necessary.
• To allow non-EU companies, for topical standards other than climate-related standards, to choose between the global consolidated approach and the mixed approach (an approach that allows the disclosure scope to be limited to impacts related to the EU) depending on their circumstances.

Please see below for the details.

• Comment on the Draft Delegated Regulation on revised European Sustainability Reporting Standards (ESRS)

Related link: European Commission's website

Contact

Corporate Accounting and Disclosure Division, Policy and Markets Bureau, Financial Services Agency

Tel +81-(0)3-3506-6000 (ext. 3861)