EU CSRD: EFRAG submits revised ESRS to the European Commission

On 3 December 2025, EFRAG submitted its technical advice on the revised European Sustainability Reporting Standards (ESRS) under the Corporate Sustainability Reporting Directive (CSRD) to the European Commission.

According to the EFRAG press release, some of the key simplifications implemented in the revised ESRS are:

• Using “usefulness of information” as a general filter with an emphasis on fair presentation

• Simplification of the double materiality assessment requirements through the provision of clearer guidance, reduced documentation, and better alignment with audit needs

• Elimination of the preference for direct data in the value chain thereby reducing the pressure for data collection

• Additional provisions to alleviate reporting burden through reliefs (e.g., specific reliefs for metrics), proportionality mechanisms (i.e., limiting information to that which is “reasonable and supportable information that is available without undue cost or effort”), and phase-ins for certain challenging disclosures (e.g., quantitative information about financial effects)

• Simplifying the structure to make the ESRS shorter, clearer, easier to understand and to implement

EFRAG state they have implemented a 61% reduction of mandatory data points as compared to the existing set of ESRS. However, a large part of this reduction is likely due to structural simplification and de-duplication and is therefore unlikely to represent an equivalent reduction in reporting burden. 

EFRAG has reiterated its focus on interoperability with the ISSB standards. However, it has flagged that some reliefs in the ESRS go beyond those in the ISSB standards, and that companies should pay attention when using reliefs if they wish to comply with the ISSB standards. 

On 4 December 2025, EFRAG has launched the ESRS Knowledge Hub, a new interactive online platform designed to help the stakeholders navigate the ESRS. The hub offers access to the adopted 2023 ESRS, draft simplified ESRS and supporting documents. Registration is required to access the hub.

Next steps

The Commission will now prepare the Delegated Act revising the existing set of ESRS based on EFRAG’s technical advice. 

As part of this process, the Commission will consult with relevant EU bodies (including the European supervisory authorities and the European Central Bank) and Member States, after which it will launch a one-month public consultation. The consultation processes will only begin after the Omnibus is finalised given the interdependencies between the ESRS and the underlying regulation. 

After the consultations, the Commission will propose the Delegated Act, which will then be subject to scrutiny by the Council and the European Parliament for four months (extendable by two months). If neither institution objects within the review period, the ESRS will be adopted and will take effect in Member State laws.

European Commissioner Maria Luís Albuquerque mentioned during her speech at the EFRAG conference on 4 December that the Commission intends to adopt the revised ESRS by mid-2026. 

For more information on the CSRD and ESRS, see our CSRD demystified materials.