meta_id 3211105

On June 3, 2026, the Japanese Bankers Association (JBA) submitted comments to the European Commission regarding the draft revised European Sustainability Reporting Standards (ESRS), released on May 6, 2026. The JBA represents 241 members, including 110 full member banks, 78 associate members, and 49 special members comprising regionally-based bankers associations. The JBA commended the European Commission's efforts to reduce administrative burdens through substantial reductions in datapoints, simplification of reporting requirements, and increased flexibility. The association welcomed the proposed simplifications, including the introduction of a top-down approach and clearer limitations on disclosure of immaterial information. However, the JBA identified concerns regarding alignment with internationally recognised sustainability reporting standards issued by the International Sustainability Standards Board (ISSB). The JBA noted that discrepancies between the ESRS and ISSB Standards may create additional disclosure burdens for reporting entities operating under both frameworks. The JBA proposed that disclosures extending beyond the scope of ISSB Standards be made voluntary as a general principle. Specifically, the association recommended that detailed disclosures regarding processes—particularly those relating to methodologies used in materiality assessments—be made voluntary. Under ISSB Standards, entities are required to disclose material risks and opportunities but not necessarily the detailed processes used to identify them, whereas the ESRS continues to require extensive process disclosures. The JBA argued that prioritising disclosure of outcomes—material topics, risks, and opportunities—while allowing process-related disclosures to remain voluntary would better serve the primary objective of providing decision-useful information while reducing documentation burdens.