What the ESRS rewrite means for your reporting
Europe’s sustainability rulebook is getting leaner: EFRAG’s draft update to the ESRS slashes mandatory datapoints by 57% and removes all voluntary disclosures, cutting the total count by 68%. The reforms, part of the European Commission’s Omnibus drive, target usability with a simpler double materiality assessment, streamlined narrative reporting, and ISSB-aligned reliefs. With consultation running to 29 September 2025 and adoption expected in early 2026, firms have a near-term window to reshape CSRD reporting architectures and push for final clarifications.
Points clés
- EFRAG’s proposed ESRS update reduces mandatory datapoints by 57% and removes all voluntary disclosures, for a total datapoint cut of 68%.
- The simplification sits within the European Commission’s Omnibus effort to ease burdens across CSRD, CSDDD, the Taxonomy Regulation, and CBAM.
- A new portal with 650+ 2025 ESRS filings shows 97% of firms engaged internal stakeholders for double materiality, only 32% reported on biodiversity, and just over half disclosed transition plans.
- Lever 1 simplifies the double materiality assessment: a top-down, business-model-first approach, “reasonable and proportionate” evidence, sub-topic-only reporting, IRO reframing, and gross vs net impact relief.
- Lever 3 consolidates Policies, Actions, Targets (PAT) into ESRS 2; firms need not report a PAT that doesn’t exist nor explain its absence—driving much of the 57% cut.
- Lever 5 introduces reliefs akin to IFRS S1/S2: “undue cost or effort,” partial-scope metrics, optional quantitative financial effects, qualitative-only resilience, and no primary-data-first hierarchy for value chain data.
- Lever 6 boosts interoperability with ISSB: closer IFRS language (“fair presentation”), adjusted GHG boundaries using financial control with an operational overlay where needed.
- The “may disclose” category is deleted; non-mandatory content moves to the Non-Mandatory Illustrative Guidance (NMIG), and Application Requirements now sit under relevant Disclosure Requirements.
- Core elements stay: double materiality remains central; Scope 3 GHGs still required; alignment continues with the European Green Deal, SFDR, and the Taxonomy; transition plans remain expected.
- Key dates: public consultation runs to 29 September 2025; EFRAG’s technical advice due 30 November 2025; final adoption targeted for early 2026, with field testing and outreach ongoing.
À retenir
Practical next steps? streamline your materiality process (top-down beats checkbox bingo), trim duplicated narratives (yes, you can stop copy-pasting policies across 42 sections), and map where the new reliefs legitimately apply—then document your judgments like an auditor is reading over your shoulder. If you report under both ESRS and ISSB, recheck assumptions on boundaries and “fair presentation” to avoid death by reconciliation. And do submit feedback before 29 September—otherwise you’ll be stuck explaining to your board why you didn’t help make the rules simpler when you had the chance; no pressure.
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