What will the updated ESRS look like? What we know so far

Spanning upwards of 1000 individual datapoints, the European Sustainability Reporting Standards ("ESRS") are one of the main areas of complexity for users required to report under the Corporate Sustainability Reporting Directive ("CSRD").

The ESRS contain the detailed list of contents and preparation guidelines which users must comply with when preparing a report under CSRD. However, the ESRS were not directly covered by the Omnibus Package proposal, and uncertainty over how these might change remains a concern for users.

The EU Commission has now engaged with EFRAG (the technocratic body responsible or preparing the ESRS) by way of a letter dated 28 March 2025, indicating a potential direction of travel in relation to this key piece of delegated regulation:

1. Timing: The Commission requested that EFRAG should provide a work plan by 15 April 2025, and provide its technical advice by 31 October 2025.
2. Substance of the revisions: The Commission reiterated the priorities it listed in its Explanatory Memorandum to the Omnibus Package, listing the following suggested changes to the ESRS:
   • Simplifying datapoints by:
     • removing those deemed least important for general purpose sustainability reporting;
     • prioritising quantitative datapoints over narrative text;
     • further distinguishing between mandatory and voluntary datapoints;
   • Promoting interoperability with other international standards;
   • Clarifying provisions deemed unclear;
   • Improving consistency between the ESRS and other pieces of EU legislation;
   • Providing clearer instructions on how to apply the materiality principle, in particular to reduce the risk that assurance service providers inadvertently encourage undertakings to report information that is not necessary or dedicate excessive resources to the materiality assessment process;
   • Simplifying the structure and presentation of the standards; and
   • Making any other changes arising from experience of the first application of ESRS.

It will remain to be seen what EFRAG will propose within the short timelines made available to it. However, EFRAG has generally been supportive of its mandate, and is working with the benefit of several rounds of detailed ESRS Q&A (now several thousands of questions long) which highlight the provisions which users most commonly struggle to apply.

Further reading:

• Read our detailed analysis of the Omnibus Package here.