EU CSRD: EFRAG agrees work plan to revise ESRS

On 25 April 2025, EFRAG announced that it has officially submitted to the European Commission its work plan outlining the steps it will take to revise and simplify the European Sustainability Reporting Standards (ESRS) under the Corporate Sustainability Reporting Directive (CSRD). 

The Commission asked EFRAG on 27 March to simplify the ESRS as part of its Omnibus simplification package – (see our previous blog post). It asked EFRAG to provide their technical advice by 31 October 2025, and to “think innovatively” in planning specific steps for the development of this advice, given that tight deadline makes it difficult to follow the usual EFRAG processes. 

According to the work plan, burden reduction shall be substantial and be performed based on an evidenced-based approach, leveraging the lessons learnt from the first wave of preparers of the CSRD reports and from the users of sustainability statements (investors and other stakeholders). EFRAG emphasised that simplification process will include not only reducing the number of data points but will also address a wide range of other issues. 

Here are the main steps of the ESRS revision process identified by EFRAG in its work plan: 

April to mid-May 2025: 

• Establishing a vision on actionable levers for substantial simplification

According to the work plan, priority will be given to establishing the strategic direction for overarching matters (e.g., materiality assessment, report structure, interaction of cross-cutting and topical standards, other key levers, interoperability with international standards). The analysis of selected technical issues will also enable EFRAG to identify additional actionable levers for substantial simplification. 

The levers initially identified are as follows:

1. Revising the presentation and architecture.
2. Addressing the most challenging provisions: this includes clarification of the application of the materiality principle and review of the most problematic datapoints, as well as consideration of the possibility to leverage on other international standards to streamline the language.
3. Evaluating general burden reduction reliefs for ESRS: this may include reliefs for reporting information about acquired businesses and disposals, certain confidential and possibly business sensitive information and metrics affected by estimation uncertainty and lack of data quality.
4. Substantially reducing the number of required datapoints (“shall”), and considering the relevance of disclosure requirements, if need be, with a focus on narrative disclosures. The reduction of datapoints shall be considered from a burden reduction angle as well as from a numerical angle.

• Gathering evidence from stakeholders, analysis of the issued reports and other sources. This includes the public call for input launched by EFRAG from 8 April to 7 May 2025 (see our previous blog post) and interviews / workshops with various stakeholders. According to the work plan, EFRAG has prepared a plan for April and May that includes one-to-one interviews and workshops (this plan is not publicly available). 

Second half of May to July 2025: drafting and approving the Exposure Drafts amending ESRS

In this step, the changes to ESRS identified in the previous steps will be implemented, to elaborate the Exposure Drafts. To speed up the process, the EFRAG Sustainability Reporting Board (SRB) will work more closely with the Sustainability Reporting Technical Expert Group (SR TEG) to provide strategic directions and the areas of focus to be followed in preparation of the Exposure Drafts. The target is to publish the Exposure Drafts for the revised ESRS by the end of July.

August and September 2025: feedback and public consultation

EFRAG stressed that given the short time available to conclude the ESRS simplification process and the time needed to analyse the public feedback, a public consultation of 120-day normally required, or even a reduced 60-day consultation period foreseen in the usual EFRAG due process are not feasible. However, EFRAG considers it necessary to run a public consultation, even if shorter than usual and in the summer period. The public consultation will take place for 30-45 days, starting at the very end of July, and will be combined with two weeks of approximately ten events, at the beginning of September, of structured public feedback outreach events.

October 2025: delivery of the revised ESRS to the Commission

The Commission has asked EFRAG to submit its final advice on the revised ESRS by 31 October. 

EFRAG has mentioned the need to monitor the legislative process on the “Content” (or “Requirements”) part of the first Omnibus package given that further changes to the CSRD might affect the revised ESRS. 

For further details of the first Omnibus package and ESRS, see our CSRD demystified materials.