EFRAG

Sustainability Report

(VSME based)

2025

Document Information

Entity Name: EFRAG
Entity Identifier: 478422212
Entity Identifier Scheme: https://e-justice.europa.eu/topics/registers-business-insolvency-land/business-registers-search-company-eu_en
Report currency: EUR
Report period: 2025-01-01 – 2025-12-31
Decimal separator: . (FULL STOP)
Report generated: 2026-04-27 14:00:34 +0000

All disclosures are related to the reporting period above unless specified otherwise.

Introduction

About EFRAG:

EFRAG is the Technical Advisor to the European Commission on corporate reporting. For financial reporting, EFRAG provides endorsement advice on IFRS Accounting Standards for use in the EU, conducive to the European public good; in sustainability reporting, EFRAG provides technical advice to the European Commission in the form of draft European Sustainability Reporting Standards (ESRS) and the Voluntary Sustainability Reporting Standard for SMEs (VSME), under a robust due process, and supports the effective implementation of both ESRS and VSME. EFRAG brings the European view to the international corporate reporting standard-setting domain.

EFRAG is a private association established in 2001 to serve the European public interest. Its Member Organisations are European Stakeholder Organisations, National Organisations and Civil Society Organisations.

EFRAG has a tiered governance structure, where EFRAG Reporting Boards and EFRAG Technical Experts Groups (TEGs) work on technical activities. These bodies are governed and overseen by the EFRAG Administrative Board, which in turn is accountable to the EFRAG General Assembly. More information can be found under disclosure C1 - Strategy: Business Model and Sustainability – Related Initiatives.

About this report:

This report represents EFRAG’s first sustainability report and has been prepared in accordance with the VSME Standard. EFRAG developed the VSME Standard under a mandate from the European Commission as part of the 2023 SME Relief Package (Action 14). EFRAG’s technical advice on the VSME Standard was adopted as a European Recommendation on 30 July 2025.

In order to support SMEs, EFRAG developed the VSME Ecosystem, which includes the VSME Digital Template and Converter. These tools, as well as other supporting materials in interactive formats, are available for free on the EFRAG Knowledge Hub. EFRAG has prepared this report using the VSME Digital Template and Converter, and it has applied additional formatting to provide greater readability to external stakeholders.

This report has been prepared on an individual basis and according to Option B (Basic and Comprehensive Modules). Being a specific type of European non-profit organisation (AISBL), the data provided for certain disclosures (including in relation to the strategy and business model) have been adapted to reflect EFRAG’s core activities. In addition, the negative responses to some of the disclosures should be seen in this context.

With this report, EFRAG intends to provide transparent communication to its stakeholders regarding EFRAG’s sustainability approach, including the strategy, key activities over the past year, and future initiatives. EFRAG wants to provide an example of the application of the VSME Standard to a European non-profit association.

Through this report, EFRAG aims to show how environmental, social, and governance (ESG) issues are embedded within its core activities. Being the first year of reporting, EFRAG acknowledges and has experienced the difficulties encountered by many SMEs in the data collection process.

One specific challenge relates to the measurement of the environmental metrics, due to the fact that, like many other SMEs, EFRAG operates in a shared-building facility and has no control over metrics such as gas consumption, water withdrawal or waste generated by other tenants. As a result of this first year reporting, EFRAG will assess how to strengthen its approach by introducing direct measurement methodologies and engaging with the building administrator to better understand impacts and identify reduction opportunities. This would facilitate EFRAG’s efforts to monitor its impacts on climate change, water, and waste generation, as well as identify mitigation actions where possible, and implement additional relevant practices, policies or future initiatives.

The report outlines how EFRAG’s employees are essential to achieving its thought leadership in corporate reporting. This is reflected in several of the policies and practices described in the report. EFRAG’s metrics related to its own workforce are particularly relevant, reflecting the organisation’s strong commitment to providing a good working environment and spirit for its employees. This commitment is demonstrated in areas such as diversity, inclusion, and work–life balance.

This report also illustrates how principles of good governance and responsible business conduct are integrated into EFRAG’s strategy and way of working. In fact, EFRAG’s governance structure and robust due process are at the core of its standard setting activities.

This report has not been subject to assurance.

[B1] — General information
- Basis for Preparation
- List of sites
[B2] — General information
- Practices, policies and/or future initiatives for transitioning towards a more sustainable economy
[B3] — Environment
[B6] — Environment
- Water Withdrawal
[B7] — Environment
[B8] — Social
[B9] — Social
- Workforce - Health and safety
[B10] — Social
- Workforce - Remuneration, collective bargaining and training
[C1] — General information
- Strategy: Business Model and Sustainability – Related Initiatives
[C2] — General information
- Description of practices, policies and/or future initiatives for transitioning towards a more sustainable economy
[C5] — Social
- Additional (general) workforce characteristics
[C6] — Social
- Additional own workforce information - Human rights policies and processes
[C7] — Social
- Severe negative human rights incidents
[C8] — Governance
- Exclusion from EU benchmarks
[C9] — Governance
- Gender diversity ratio in the governance body

[B01.000] - General information - Basis for Preparation ⮌

Option B (Basic Module and Comprehensive Module): Basis for preparation (Basic Module Only or Basic & Comprehensive Module)

Sustainability report prepared on an individual basis: Basis for reporting (consolidated or individual basis)

NO: Report contains disclosures from the previous reporting period that remain unchanged

None: List of omitted disclosures deemed to be classified or sensitive information

other (please specify the legal form in the row below): Undertakings legal form

AISBL - International non-profit association: Other undertaking's legal form

NACE N - 70.20 Business and other management consultancy activities: NACE sector classification codes

€ 9,007,246.23: Size of balance sheet (total assets)

€ 16,715,700.80^[1]: Turnover

59.00: Number of employees

At the end of the reporting period: Employee counting methodology

Headcount: Type of number of employees

Belgium: Country of primary operations and location of significant assets

^[1] EFRAG has as revenue EFRAG Member Organisations contributions and grants.

[B01.200] - General information - List of sites ⮌

Identifier of site	2025-01-01 – 2025-12-31
Identifier of site	Address of site	Postal code of site	City of site	Country of site	GPS Location of site
1	Square de Meeus 35	1000	Bruxelles	Belgium	50.8405341,4.3696577

[B02.000] - General information - Practices, policies and/or future initiatives for transitioning towards a more sustainable economy ⮌

Climate change Water and marine resources Circular economy Own workforce Business conduct: Sustainability issues addressed by practice, policy and/or future initiative

YES: Practice, policy and/or future initiative is publicly available

NO: Undertaking has set a target which is related to a policy

[C02.000] - General information - Description of practices, policies and/or future initiatives for transitioning towards a more sustainable economy ⮌

The following disclosure outlines EFRAG’s current practices, policies and future initiatives for the following issues (B2):
• Climate change • Pollution • Water and Marine Resources • Circular Economy • Own Workforce • Business Conduct
We are conscious about the environment and our impact on it (Climate Change, Water, Circular Economy). Therefore we:
Prioritise structural measures
Strive to operate in energy-efficient, low-emission office spaces and incentivise environmentally preferable commuting (e.g. e-bike, public transport support, remote work possibility including from abroad).
Favour energy-efficient and renewable energy–powered server and cloud solutions.
Defined a Travel policy to reduce the environmental impact of employee travel.
Reduce resource consumption at source (energy & materials)
Invest in digital systems to reduce paper consumption (e.g. digital business cards, printers accessible only through working badges).
Purchase office supplies made from recycled or certified materials (e.g. FSC, PEFC, EcoLabel).
Provide drinkable tap water using built-in filters to reduce plastic bottle use.
Promote circularity and waste reduction
Return old IT equipment to suppliers for reuse, repair or responsible disposal.
Collect printer cartridges in dedicated bins and return them for recycling.
Encourage black-and-white printing and use printers with low-ink detection to minimise waste.
Provide an office kitchen with reusable kitchenware to avoid single-use items.
Favour wired devices (e.g. headphones, mice) to reduce battery waste.
Encourage sustainable everyday behaviours
Use catering services offering locally sourced vegetarian and vegan food.
Have dedicated in-office collection points for e-waste and batteries.
As this is our first year of reporting, we are strengthening our approach and plan to introduce the following measures:
Improve measurement methodologies for environmental metrics to better understand impacts and identify reduction opportunities.
Strengthen engagement with suppliers, in particular the building administrator, to identify and implement impact reduction measures.
Obtain a dedicated parking place equipped with electric vehicle charging.
Establish an annual “data cleaning day” to improve our office’s energy efficiency and reduce energy use.
We provide a good working environment and spirit to EFRAG’s employees:
We have a Human Resources Policy that covers:
Recruitment: promoting diversity among our workers, by rejecting all forms of discrimination and by giving equal chance for employment to candidates with various backgrounds and origins, independently of the gender.
Annual performance reviews process.
Remuneration: defining the salary and benefits policy, including health insurance and pension.
Work-life balance measures such as teleworking policy including working from abroad. This provides flexible working hours, remote work options and family-friendly practices to support employees in reaching work-life balance.
Health and safety:
health and safety training provided to employees
reviewing Emergency Preparedness Plans, such as evacuation routes, communication protocols and fire drills
a third-party, Mensura, is engaged as an external services provider for prevention and protection at work. This is to comply with the Belgian health and safety, including wellbeing, regulation.
Support employee training and development by:
delivering induction and onboarding programmes for new recruits.
offering internal training to EFRAG employees on sustainability and financial reporting matters.
facilitate external qualifications such as CFA, ACCA, CPA, GRI.
We have further plans to develop the following policies (Own Workforce):
Designate an employee responsible for occupational health and safety.
Formalise training programmes (for example, internal training through Educational week or modules) on identified needs.
Develop and formalise the complaints handling mechanism for employee-related matters leveraging from the existing practices (for example, the DEI champions already in place).
We organise our work with integrity and transparency (business conduct), as such we:
Defined a Mission statement.
Adopted a due process to ensure transparent, independent, and evidence-based standard-setting for financial and sustainability reporting (ESRS) and report on an annual basis to the EFRAG General Assembly and publish this report on our website. The EFRAG Administrative Board is responsible for EFRAG’s due process and the due process oversight of all EFRAG's technical bodies and is assisted in this role by the Due Process Committee. Due process procedures for Financial Reporting and Sustainability Reporting are approved by the General Assembly. In addition we defined a Field Work Policy for the Financial Reporting pillar.
Adopted Internal Rules that define the organization's governance bodies, its working rules and procedures, approved by the EFRAG General Assembly. In addition, we defined a Conflict of interest policy, and as well a Policy for Approval by Written Procedure by the EFRAG FRB.
Stimulated gender diversity within the governance bodies.
Adopted a Privacy policy.
Adopted a Policy on EFRAG Public Transparency register.
We have further plans to introduce (Business Conduct) in 2026:
A Code of conduct, leveraging on the already existing policies
AI and cyber security training to avoid phishing and cyber attacks
Across environmental, social and business conduct issues for 2026 we will formalise the EFRAG Sustainability Policy (including health and safety and well-being) based on the work of a cross-functions internal working group. The policy will leverage on the practices described above and will be adopted by the EFRAG Administrative Board.: Description of practices, policies and/or future initiatives

The EFRAG Administrative Board holds the responsibility for policy adoption. The EFRAG CEO and EFRAG SR TEG and FR TEG Chairs hold the responsibility for policy implementation.: Most senior level within its employees that is accountable for policies

[B03.000] - Environment - Total Energy Consumption ⮌

111.35 MWh^[2]: Total energy consumption

[B03.200] - Environment - Estimated Greenhouse Gas Emissions ⮌

	2025-01-01 – 2025-12-31
	tCO2e
	Currently stated
Gross Scope 1 greenhouse gas emissions	0.00
Gross location-based Scope 2 greenhouse gas emissions	20.00
Total (gross) location-based Scope 1 and Scope 2 GHG emissions	20.00

[B03.300] - Environment - Greenhouse Gas Emissions intensity ⮌

0.0000012 tCO2e per €: Location-based Scope 1 and Scope 2 Greenhouse Gas Emissions intensity Calculation: (Scope 1 + Scope 2 GHG emissions location-based) / turnover

^[2] Energy consumption comprises electricity invoiced directly to EFRAG and a proportion of total building gas consumption, allocated based on EFRAG’s contractual cost share (11.18%).

[B06.000] - Environment - Water Withdrawal ⮌

308.34 m³^[3]: Total amount of water withdrawn from all sites

0.00 m³^[4]: Amount of water withdrawn at sites located in areas of high water-stress

[B07.000] - Environment - Description of circular economy principles ⮌

YES: Undertaking applies circular economy principles

Refurbishment of company computers and other IT equipment Reduction of single use cutlery through provided kitchen utensils to enhance reusability of products and ensure minimisation of waste Collecting and recycling of 'municipal' waste: Description of how circular economy principles are applied

[B07.100] - Environment - Breakdown of waste by type ^[5] ⮌

Type of waste	2025-01-01 – 2025-12-31
	kg
	Waste diverted to recycle or reuse (mass)	Waste directed to disposal (mass)	Total waste recycled, reused and directed to disposal (mass)
08 03 17 - Hazardous - Waste printing toner containing hazardous substances	1.25	0.00	1.25
15 01 01 - Non-Hazardous - Paper and cardboard packaging	2,440.15	0.00	2,440.15
15 01 02 - Non-Hazardous - Plastic packaging	5.87	0.00	5.87
15 01 06 - Non-Hazardous - Mixed packaging	258.26	0.00	258.26
15 01 07 - Non-Hazardous - Glass packaging	153.04	0.00	153.04
16 02 13 - Hazardous - Discarded equipment containing hazardous components (3) other than those mentioned in 16 02 09 to 16 02 12	19.01	0.00	19.01
16 05 04 - Hazardous - Gases in pressure containers (including halons) containing hazardous substances	0.15	0.00	0.15
17 04 05 - Non-Hazardous - Iron and steel	40.25	0.00	40.25
20 01 08 - Non-Hazardous - Biodegradable kitchen and canteen waste	397.13	0.00	397.13
20 01 21 - Hazardous - Fluorescent tubes and other mercury-containing waste	3.04	0.00	3.04
20 01 35 - Hazardous - Discarded electrical and electronic equipment other than those mentioned in 20 01 21 and 20 01 23 containing hazardous components (3)	118.51	0.00	118.51
20 01 38 - Non-Hazardous - Wood other than that mentioned in 20 01 37	78.26	0.00	78.26
20 01 39 - Non-Hazardous - Plastics	39.80	0.00	39.80
20 03 01 - Non-Hazardous - Mixed municipal waste	540.83	0.00	540.83
20 03 07 - Non-Hazardous - Bulky waste	38.57	0.00	38.57

[B07.200] - Environment - Total Hazardous and Non-Hazardous waste ⮌

141.96 kg^[5]: Total Hazardous waste generated (mass)

3,992.16 kg^[5]: Total Non-Hazardous waste generated (mass)

4,134.12 kg^[5]: Total waste generated (mass) Calculation: total Hazardous waste generated + total Non-Hazardous waste generated (mass)

^[3] Water is based on a proportion of total water withdrawal of the building, allocated based on EFRAG’s contractual cost share (11.18%).

^[4] According to the Water Exploitation Index plus (WEI+), EFRAG is not located in an area of high-water stress.

^[5] Waste is based on a proportion of total waste management of the building, allocated based on EFRAG’s contractual cost share (11.18%). This figure seems excessive, especially for hazardous waste and paper. EFRAG has no control over waste generated by other tenants. EFRAG will assess whether a direct measurement of the waste it generates can be implemented in 2026.

[B08.000] - Social - Workforce - General characteristics: type of contract ⮌

49.00: Number of permanent contract employees

10.00: Number of temporary contract employees

[B08.100] - Social - Workforce - General characteristics: gender ⮌

27.00: Number of male employees

32.00: Number of female employees

0.00: Number of other gender employees

0.00: Number of non-reported gender employees

[B08.200] - Social - Workforce - General characteristics: country of employment ⮌

Country of employment contract	2025-01-01 – 2025-12-31
Country of employment contract	Number of employees for country of employment contract
Belgium	54.00
Germany	2.00
Spain	1.00
France	1.00
Portugal	1.00

[B08.300] - Social - Workforce - General characteristics: turnover rate ⮌

12.70 %: Employee turnover rate Calculation: (number of employees who left during the reporting period / average number of employees during the reporting period) * 100

[B09.000] - Social - Workforce - Health and safety ⮌

0.00: Number of recordable work related accidents in the reporting period

0.00: Rate of recordable work related accidents in the reporting period Calculation: (number of recordable work-related accidents in the reporting year / total number of hours worked in a year by all employees) * 200000. The amount of 200000 hours represents the total annual working hours of 100 employees (40 hours per week for 50 weeks per year) and serves as the standard base for calculating the incidence rate over a year, applicable to undertakings with up to 250 employees

0.00: Number of fatalities as a result of work-related injuries and work-related ill health

[B10.000] - Social - Workforce - Remuneration, collective bargaining and training ⮌

YES: Employees receive pay equal or above minimum wage determined by national law or collective bargaining agreement

9.78 %^[6]: Percentage gap in pay between female and male employees Calculation: ((average gross hourly pay level of male employees - average gross hourly pay level of female employees) / average gross hourly pay level of male employeees) * 100

91.53 %^[7]: Percentage of employees covered by collective bargaining agreements Calculation: (number of employees covered by collective bargaining agreements / total number of employees) * 100

20.00: Average number of annual training hours per male employee

45.00: Average number of annual training hours per female employee

0.00: Average number of annual training hours per other gender employee

0.00: Average number of annual training hours per non-reported gender employee

^[6] Even though this is only required for undertakings with more than 150 employees, EFRAG discloses the unadjusted gender pay gap in the interest of full transparency. This figure reflects the differing proportions of men and women across various roles, with a higher proportion of men in management positions.

^[7] 91.53% of EFRAG’s employees are covered by a collective bargaining agreement which takes the form of Commission Paritaire (CP) 337. All organisations in Belgium according to national law have to be part of a CP, for EFRAG is the CP 337 - Commission paritaire auxiliaire non-marchand.

[C01.000] - General information - Strategy: Business Model and Sustainability – Related Initiatives ⮌

EFRAG’s mission is to serve the European public interest in both financial and sustainability reporting by developing and promoting European views in the field of corporate reporting. EFRAG builds on and contributes to progress in corporate reporting. EFRAG’s activities are organised in two pillars: A Financial Reporting Pillar: influencing the development of IFRS Accounting Standards from a European perspective and how they contribute to the efficiency of capital markets, and providing endorsement advice on (amendments to) IFRS Accounting Standards to the European Commission. Secondly, a Sustainability Reporting Pillar: developing draft European Sustainability Reporting Standards (ESRS) and the Voluntary Sustainability Reporting Standard for SMEs (VSME), and related amendments for the European Commission and providing implementation support for ESRS and the VSME Standard through the development of supporting materials and tools, such as the EFRAG Knowledge Hub.: Description of significant groups of products and/or services offered

EFRAG operates in the European corporate reporting and standard-setting market, engaging with a broad range of stakeholders including public bodies, businesses, regulatory bodies, standard-setters, and professional networks. In both the Financial Reporting Pillar and the Sustainability Reporting Pillar, EFRAG seeks input from all stakeholders and obtains evidence about specific European circumstances throughout the standard-setting process. Its legitimacy is built on excellence, transparency, governance, due process, public accountability and thought leadership.: Description of significant market(s) the undertaking operates in e.g. B2B, wholesale, retail, countries

EFRAG is committed to a transparent and inclusive due process, ensuring all stakeholders have the opportunity to contribute. This commitment is achieved through public technical discussions, open consultation processes, field tests, and the comprehensive publication of relevant documents. A rigorous and transparent due process is fundamental to the long-term credibility and independence of EFRAG’s standard-setting activities. EFRAG Reporting TEG establishes Working Groups (expert working groups, advisory panels and communities) to support its work in order to obtain advice from experts on a particular area or aspect of corporate reporting.: Description of main business relationships (e.g. key suppliers, customers distribution channels) e.g. key suppliers, customers distribution channels and consumers

EFRAG's 2024-2027 Strategy outlines specific goals and objectives to be achieved in the next four years and serves as a roadmap for EFRAG to navigate through the challenging and rapidly changing environment. This Strategy will, among other things, guide and help EFRAG in identifying priorities, deciding on how to use its resources efficiently, and making informed decisions. It will also help all those working with EFRAG (i.e., EFRAG Member Organisations, working groups, staff, etc) understand what EFRAG wants to achieve and, consequently, align efforts towards common targets and goals. The EFRAG 2024-2027 Strategy is divided into two main areas: Strategic objectives and priorities related to EFRAG's technical work and advice to the European Commission, which encompasses a financial reporting and sustainability reporting pillar. Objectives and priorities related to EFRAG's governance structure, funding and administration as conditions for EFRAG's technical work and advice to the European. These will help in ensuring that future IFRS Accounting Standards are endorsed and European Sustainability Reporting Standards (ESRS) are developed using an inclusive and rigorous due process and that EFRAG is an attractive organisation to work for now and in the future. These goals and objectives are particularly important so that EFRAG can effectively manage the aftermath of its governance reform, which integrated the sustainability reporting pillar into the EFRAG governance structure.: Description of key elements of strategy that relates to or affects sustainability issues

[C05.000] - Social - Additional (general) workforce characteristics ⮌

0.71: Female-to-male ratio at management level for the reporting period Calculation: number of female employees at management level / number of male employees at management level

0.00 ^[8]: Total number of self-employed workers without personnel that are working exclusively for the undertaking

0.00: Total number of temporary-workers provided by undertakings primarily engaged in employment activities

^[8] EFRAG did not have self-employed workers without personnel that were working exclusively for EFRAG. However, EFRAG had in 2025 22 self-employed workers with a contract with a range of 50-80% FTE and a range of duration between 2 and 12 months. These self-employed workers were pilot experts in the context of EFRAG's pilot grant received by the European Parliament.

[C06.000] - Social - Additional own workforce information - Human rights policies and processes ⮌

NO: Undertaking has a code of conduct or human rights policy for its own workforce

NO: Undertaking has a complaint handling mechanism for its own workforce

[C07.000] - Social - Severe negative human rights incidents ⮌

NO: Undertaking has confirmed human rights incidents in its own workforce

NO: Undertaking aware of any confirmed incidents involving workers in the value chain, affected communities, consumers and end-users

[C08.100] - Governance - Exclusion from EU benchmarks ⮌

NO: Undertakings are excluded from any EU reference benchmarks that are aligned with the Paris Agreement

[C09.000] - Governance - Gender diversity ratio in the governance body ⮌

0.25: Gender diversity ratio in governance body Calculation: number of female board members / number of male board members

The European Union flag

EFRAG is funded by the European Union through the Single Market Programme in which the EEA-EFTA countries (Norway, Iceland and Liechtenstein), as well as Kosovo participate.

Any views and opinions expressed are however those of the author(s) only and do not necessarily reflect those of the European Union, the European Commission or of countries that participate in the Single Market Programme. Neither the European Union, the European Commission nor countries participating in the Single market Programme can be held responsible for them.

For further details please contact info@efrag.org

This report contains 115 XBRL facts.