Although he may be the Environment Manager of a well-established CAC40 institution, the Bouygues group, Fabrice Bonnifet is not a fan of conventional speeches. There is no question for this president of the College of Directors of Sustainable Development – 320 member companies – to complain about the new “green” regulations which many are making a mountain of. In France, a senatorial mission has even been launched with this concern: “CSRD: too much complexity for businesses?” This European directive – Corporate Sustainability Reporting Directive – will force companies to undertake an unprecedented exercise of transparency on their impact on nature and society. A few days before its entry into force, at the start of 2024, the point of view of an expert which contrasts with the ambient cries of outrage.
L’Express: What will happen on January 1, 2024 for European companies?
Fabrice Bonnifet: The first year of application of the CSRD will begin, for companies with more than 40 million euros in turnover or more than 250 employees. SMEs and ETIs will have a one-year reprieve to prepare for this transition [NDLR : à terme, 50 000 entreprises seront concernées]. We have been working on this for months, even several years, in order to be able to produce in 2025, for the 2024 financial year, the sustainability report which will certify that the requirements are respected. Potentially, 1,178 pieces of data will be applicable, depending on the analysis of their materiality [NDLR : leur pertinence selon les activités de l’entreprise]. Some are quantitative – consumption of energy, water, waste production, etc. -, others are qualitative, such as the action plans on which to communicate or commit to protect a resource or change a business model. This information will be audited by an independent third party.
How prepared are businesses?
In France, the extra-financial performance declaration (DPEF) has already existed for six years, and before it, article 225 of the Grenelle II law was applied. Large companies therefore already have a quarter, or even a third, of the requested data. Some countries are starting from zero and for them, this is a quantum leap! But the companies concerned are not required to be fully compliant with the CSRD from the first year – the legislator gives the possibility of establishing compliance plans – especially as we move into a dual materiality regime [NDLR : les conséquences du changement climatique sur les résultats financiers mais aussi les impacts de l’entreprise sur son environnement]. These are new issues, we are changing dimensions in risk analysis.
SMEs will not be subject to the CSRD immediately, but they already fear its indirect effects. A justified fear?
No, we are not going to ask our small suppliers to apply the CSRD, that makes no sense. On the other hand, SMEs will be much more concerned by another draft European directive in preparation: the CSDDD, which concerns the duty of extended vigilance of companies with regard in particular to respect for human rights and protection of the environment. , and the climate in particular.
A senatorial mission was launched to assess the complexity of implementing the CSRD for businesses. Some employers’ associations denounce the accumulation of environmental and social standards and obligations. What do you think ?
It is true that there is almost four times more data to provide, on average, than with the DPEF. This directive has an impact on the information system, the assessment of risks and opportunities. It will also call on the financial management, because it will be necessary to quantify the potential impact, positive or negative, in euros. It is not only a reporting standard but an incentive for business model transformation. There is a much stronger strategic dimension. It has long been believed that companies would self-regulate. In fact, the most responsible among them demand fair regulation, with a level playing field for all. Of course, all these obligations arrive at the same time, because until now there has been no universal framework to protect the climate, resources and biodiversity. Now that we’re up against the wall, we need to speed up. When section 225 came out, companies said they were never going to get there. Same with the DPEF. CSRD is not insurmountable.
Is this not, however, a new blow to the competitiveness of European companies?
Many members of the College of Sustainable Development Directors would say that the CSRD is a boon for Europe, which does not have significant reserves of oil, gas or mineral resources. This will make us more competitive with global companies that have not understood the importance of sobriety. These standards should not be taken as a constraint but as an opportunity to develop more resilient business models, and above all more compatible with planetary limits.
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