EFRAG releases revised ESRS Exposure Drafts

As a result, in November 2024, the European Commission announced an intention to introduce a proposal to amend three key pillars of the European Green Deal through an Omnibus package. These key pillars are the CSRD, the Corporate Sustainability Due Diligence Directive (CSDDD) and the Taxonomy Regulation.

The Omnibus package, released in February 2025, has resulted in several sets of proposals to date – revising the existing European Sustainability Reporting Standards (ESRS) is one element of the proposals. For this, the European Financial Reporting Advisory Group (EFRAG) have been tasked by the European Commission to provide technical advice for the adoption of a delegated act which will revise and simplify the existing ESRS.

On 31 July 2025, EFRAG issued Exposure Drafts (EDs) revising all 12 existing ESRS, with a 60-day public consultation period. As well as 12 amended ESRS EDs, they have issued the Basis for Conclusions, Log of Amendments and other helpful examples and summaries. Response to these EDs were made via a consultation survey until September 29 through the ESRS simplification webpage.

Summary of modifications

In order to simplify the ESRS without compromising the objectives of the Green deal, the EDs propose to revise the ESRS by utilising six ‘top-down’ levers of simplification and a ‘bottom-up’ review of all datapoints. These are intended to reduce complexity, and are summarised below. Note that this summary is not an exhaustive list of all the revisions set out in the EDs.

‘Top-down’ levers of simplification 

‘Bottom-up’ review of all datapoints

Many stakeholders have been critical of the large number of ESRS datapoints and the resulting reporting burden. This assertion was supported by EFRAG’s data gathering efforts which noted that stakeholders believe that narrative datapoints are too granular, preferring a more principles-based approach, and that many datapoints could be removed without impacting the quality of data and information.

To address these concerns, in addition to the levers discussed above, EFRAG has cut mandatory datapoints by 57% and the full set of disclosures, both mandatory and voluntary, by 68%. This was achieved by making revisions that reflect a less granular approach to narrative disclosures for PATs and eliminating the least relevant datapoints – those that do not directly meet the disclosure objectives. For a full breakdown of eliminated datapoints, please review the Log of Amendments for each respective Standard.

Next steps

The key amendments summarised above are proposed in the EDs, with changes from the original ESRS documented in the Log of Amendments. Feedback was provided via completing the consultation survey through EFRAG’s webpage. The survey itself contained 30 questions in which respondents could provide their feedback – respondents could choose which questions they respond to. There was also an optional section to provide more detailed comments at the Disclosure Requirement level or paragraph of the ED, which could be given using an Excel spreadsheet provided.

The consultation period was open for 60 days until 29 September 2025. Following the close of the consultation period, EFRAG will review the results of the survey and provide its final technical advice on the ESRS to the European Commission by 30 November 2025.

Our thoughts

We are pleased to see the progress that EFRAG is making towards their ESRS simplification goal with these revisions. As the revisions are very significant, it is too early to fully understand the impact they will have on alleviating the reporting burden. However, we support their overall goal of achieving simplification of the ESRS and hope that, particularly for smaller entities, these clarifications will make it easier for reporting entities to understand and implement the Standards.

However, we believe that the volume of revisions will make the process of assessing these proposed changes difficult in the time frames provided. We understand this is a result of the tight timeline that EFRAG has to issue the final report to the European Commission at the end of November, but this timeline may not allow for adequate due process.

We have published several other alerts related to the Omnibus package. For more information, click here: 

• Sustainability Alert: European Commission adopts ‘quick fix’ amendments to ESRS for Wave 1 entities
• Sustainability Alert: The European Commission adopts a new Delegated Act to Simplify EU Taxonomy reporting requirements
• Sustainability Alert: Omnibus package stop-the-clock proposal adopted by European Parliament

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