On 31 July 2025, the European Financial Reporting Advisory Group (EFRAG) released the Exposure Drafts of the amended European Sustainability Reporting Standards (ESRS). The revisions follow the European Commission’s ESG Omnibus Simplification Package (26 February 2025), which aims to reduce administrative and reporting burdens. Although still in draft form, the amended ESRS offer insight into EFRAG’s proposed simplifications and help Corporate Sustainability Reporting Directive (CSRD) preparers anticipate upcoming changes. As the amended ESRS are still drafts, FY 2025 reporters (wave 1) must continue using the first set of ESRS (2023 ESRS), also considering the additional relief granted by the Commission in July 2025 under the “quick fix” delegated act. Refer to the “What is next” section for expected timing of the amended ESRS finalization.
The revisions follow the European Commission’s 26 February 2025 publication of the first ESG Omnibus Simplification Package aimed at simplifying the administrative and reporting burden of organisations while still meeting the core policy objectives of the European Green Deal. The revised ESRS are now open for public comment. The public comment period closes xx September 2025. EFRAG is required to share the revised ESRS with the European Commission by the end of November 2025. The European Commission will review this submission and may update the standards before adopting the revised ESRS in a delegated act. Adoption of the delegated act will include setting the effective date for the revised ESRS. It is expected that this will occur once the final negotiations on the directive amending CSRD are complete.
Considering the timing of this process, the revised ESRS will not be available for current CSRD reporters (wave 1) for use in their FY25 reports. They should continue to report using the first set of ESRS, with consideration of the additional reliefs that the Commission granted in April and July 2025, as part of the “stop-the-clock” and “quick fix” legislative acts.
Within the amended ESRS Exposure Drafts the mandatory datapoints are reduced by 57%. Many of the deleted datapoints relate to disclosures on policies, actions, and targets, where a less prescriptive and more principles-based approach has been proposed.
The amended ESRS also follow a simpler structure and clarify certain concepts that resulted in confusion under the 2023 ESRS. EFRAG introduced six levers for simplification, which are summarized below, including several examples (non-exhaustive). The actual overview of changes applicable to an organisation needs to be determined on a case-by-case basis.
The simplification of the DMA under the amended ESRS aims to reduce complexity and shift focus from procedural compliance to meaningful, decision-useful sustainability reporting. For example, a new section in ESRS 1 introduces “practical considerations” for conducting the DMA. This emphasizes a top-down approach starting from the business model to identify obvious material topics. For these obviously material topics, organisations can collect less evidence to support conclusions compared to the 2023 ESRS requirements (eliminating unnecessary scoring). Another example is clarification on how to consider remediation, mitigation and prevention policies and actions in assessing the materiality of impacts (in practice known as the “gross versus net” issue).
To improve readability and integration of sustainability statements within corporate reporting, certain reporting flexibilities are now clarified. An example is allowing an organisation to disclose information just once, in aggregate, for information related to policies, actions, and targets if organisations apply these to more than one material topic. This aims to improve readability, reduce the reporting burden, and help organisations better tell their sustainability story.
In the 2023 ESRS, the Minimum Disclosure Requirements (MDRs) on policies, actions, and targets within ESRS 2 are duplicated in topical standards, while the topical standards included additional, non-essential disclosure requirements. Within the amended standards, the MDRs are renamed to General Disclosure Requirements (GDR), where the datapoints to be reported are reduced to essential disclosures only. For example, describing the scope of the policy is seen as essential and is therefore still required in the amended draft ESRS. Disclosing the most senior level individual in the undertaking’s organisation that is accountable for the implementation of the policy is considered a non-essential disclosure and is therefore removed. This creates a shift towards a less prescriptive and more principles-based disclosure model.
The structure of the standards has changed, separating clearly mandatory and non-mandatory disclosure requirements. The mandatory guidance (application requirements) is now included immediately after the related disclosure requirements. Additionally, the majority of the “may disclose” datapoints are removed to avoid misinterpretation and to clarify what is truly required versus optional. The non-mandatory guidance has been moved to separate “Non-Mandatory Illustrative Guidance” documents.
EFRAG introduces a range of burden-reduction reliefs to simplify reporting, including broader use of IFRS-aligned provisions such as “undue cost and effort” when reporting metrics and the disclosure of ranges for quantitative anticipated effects. Another important change is a new relief when organisations encounter data quality issues for own operations and value chain metrics, where a partial metric scope is allowed when accompanied by the required disclosures and data availability improvement plan.
EFRAG has drafted the amended ESRS so that they align more closely with IFRS S1 and S2 by updating terminology and harmonizing disclosure requirements to enhance interoperability. Examples are the clarification of fair presentation in line with IFRS S1 (General Requirements for Disclosure of Sustainability-related Financial Information) and alignment with the GHG protocol by applying the financial control approach for emission reporting.
Even though the Exposure Drafts are subject to a consultation period and thereby potential changes, organisations should use these drafts to prepare in time for upcoming reporting periods (does not apply to FY 2025 reporting). We want to highlight three key considerations:
(For wave 2 companies - future reporters with a CSRD obligation for fiscal years beginning on or after 1 January 2027):
The information materiality assessment determines what organisations need to disclose about their material sustainability topics. A reassessment of information materiality enables organisations to direct reporting efforts to the remaining disclosure requirements in the amended ESRS, saving time and effort by no longer focusing on requirements from the 2023 ESRS that have been removed. For example, organisations can focus their efforts on improving the data quality of a strategic metric instead of drafting detailed narrative disclosures that are no longer mandatory. This assessment is foundational for wave 2 companies to plan and budget their CSRD readiness activities for 2026 and 2027. This will apply to wave 1 organisations (current CSRD reporters) in future years when the amended ESRS apply.
(For wave 1 and wave 2 organisations)
The CSRD goes beyond reporting. This was always the case, but the revised ESRS and the reduction in datapoints provide an opportunity for organisations to put renewed efforts into defining their policies, setting targets and implementing action plans to make progress on their material impacts, risks, and opportunities. Dedicated attention can be given to essential activities, as required under other regulations, like developing a climate transition plan and supply chain due diligence to focus on operational improvements and reduce risks.
(For wave 2 companies)
The DMA is the cornerstone of the CSRD. When refreshing the DMA, organisations should take note of the additional guidance once the amended ESRS are finalized to focus on genuinely relevant sustainability matters. EFRAG provides new practical guidance as well as clarifications of certain elements that were unclear in the past. This will apply to wave 1 organisations in future years when the amended ESRS apply.
These steps will help organisations stay aligned with evolving expectations and prepare in time for the finalization of the ESRS (expected in 2026). We are ready and able to help you assess the impact of these changes on your organisation and how to best prepare for CSRD reporting in an efficient but strategically relevant way.
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