ESG-benchmark as a strategic tool
Advisory - SustainabilityESG benchmarking is developing into a valuable strategic tool for strategy, innovation and stakeholder trust in this playing field.
19 Jan 2026 8 min read

The European Financial Reporting Advisory Group (EFRAG) has submitted its technical advice to the European Commission on the draft simplified European Sustainability Reporting Standards (ESRS). This is a key step in the Omnibus package, which was released in February 2025, after a call from stakeholders and ‘wave 1’ reporters that the ESRS were overly complicated and created a huge burden for companies.
Since the Corporate Sustainability Reporting Directive (CSRD) initially came into force on 1 January 2023, there have been increasing demands in the European Union to streamline the requirements and reduce the reporting burden associated with sustainability reporting. 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 ESRS is one element of the proposals. For this, the 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. On 3 December 2025, after considering the feedback received from the consultation, EFRAG submitted its technical advice to the European Commission (EC) on the draft simplified ESRS.
In order to simplify the ESRS without compromising the objectives of the EU Green deal, the EFRAG revisions to the ESRS focus on several key areas of simplification. These are intended to reduce complexity and are summarised below. Note that this summary is not an exhaustive list of all the changes set out in the revised ESRS.
| Area | Simplification |
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Simplification of the Double Materiality Assessment (DMA)
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Better readability/conciseness of the sustainability statements and better inclusion in corporate reporting as a whole
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Critical modification of the relationship between Minimum Disclosure Requirements (MDRs) and topical specifications
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Improved understandability, clarity and accessibility of the Standards
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Introduction of other suggested burden-reduction reliefs
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Enhanced interoperability
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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 changes discussed above, EFRAG has cut mandatory datapoints by 61% and eliminated voluntary disclosures, resulting in a 70% reduction to the full set of disclosures. 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.
The EC now needs to adopt a new Delegated Act revising the first set of ESRS based on EFRAG’s technical advice, in order for this to be transposed into legislation.
We are pleased to see that EFRAG have now completed their part in the ESRS simplification by providing the technical advice to the EC. 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 the EC’s overall goal of achieving simplification of the ESRS and hope that these clarifications will make it easier for reporting entities to understand and implement the Standards.
We have published several other alerts related to the Omnibus package. For more information, click here:
ESG benchmarking is developing into a valuable strategic tool for strategy, innovation and stakeholder trust in this playing field.
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