EFRAG work plan aims to reduce data requirements in CSRD reports

As part of the Omnibus procedure, the European Commission has instructed the European Financial Reporting Advisory Group, or EFRAG, to revise the first set of European Sustainability Reporting Standards (ESRS) under the CSRD. EFRAG has until 1 November 2025 to develop a proposal for amending the ESRS. The aim is to reduce disclosure requirements in CSRD reports and thereby reduce administrative and cost burdens for companies.

ESRS reform mandate

EFRAG submitted a work plan for revising the ESRS (European Sustainability Reporting Standards) to the European Commission on 25 April 2025.

The CSRD (Corporate Sustainability Reporting Directive, Directive (EU) 2022/2464) requires a wide range of companies to report annually on key sustainability aspects based on uniform European standards. On 31 July 2023, the European Commission published the first set of ESRS, which is scheduled to be substantially revised this year following on the basis of the first Omnibus package published on 26 February 2025 (see our article). On the one hand, the large amount of information is to be reduced, without losing sight of the objective of the CSRD: to create more transparency and comparability in the field of sustainability reporting. EFRAG intends to incorporate the initial reporting experiences of the first-wave reporting companies covering the 2024 financial year. To ensure that the revisions to the standards are practical and effective, companies will be actively involved through public consultation on the drafts and the evaluation of stakeholder feedback.

Planned key areas of the ESRS revision include:

• Simplifying the structure and presentation of the standards
• Reducing mandatory disclosures, especially those of lower relevance
• Prioritising quantitative data and measurable data over descriptive narratives
• Drawing a clearer distinction between mandatory and voluntary disclosures
• Providing clear guidance on the materiality assessment to avoid unnecessary reporting and audit effort
• Improving consistency with other pieces of EU legislation
• Enhancing interoperability with international standards

EFRAG’s Progress Report of 20 June 2025

On 20 June 2025, the EFRAG published a report outlining the progress made on the revision of the ESRS. The report sets out some of the measures by which EFRAG wishes to streamline the standards. This includes for example:

• Improved readability and integration in corporate reporting: Detailed information and disclosures related to EU Taxonomy are to be presented in separate sections or annexes for greater visibility, while immaterial disclosures are to be placed in separate sections or annexes.
• Modification of mandatory disclosure requirements: Complexity and duplications are to be reduced in the reporting. The number of data points is to be reduced, and disclosures on policies, actions and targets are to be made only once, and only if they relate to essential sustainability aspects.
• Enhancing understandability, clarity and accessibility of the standards: To achieve this aim, the list of voluntary disclosures in CSRD reports will be revised and where appropriate significantly reduced. The structure of the reporting standards will be amended, enabling mandatory and voluntary disclosures to be clearly separated.
• Simplifying the double materiality assessment: EFRAG emphasises that the starting point for the double materiality assessment is an analysis of the company’s business model (“top-down” approach). A materiality filter is to be introduced for all data points.
• Improving alignment with international standards: Finally, interoperability of the ESRS with international standards, particularly those of the International Sustainability Standards Board (ISSB), is to be increased. For example, the “undue cost and effort” from these standards is to be adopted, under which undertakings only have to use information in their reports that is available to them without unreasonable cost and effort.
• Additional reliefs: Companies will not need to report immaterial data points if reliable data is lacking and may rely more on estimates in the future.

Timeline for revision and initial comments

EFRAG is pursuing an ambitious timeline. The revision process is intended to be transparent and to actively involve businesses, supervisory authorities, civil society and experts. To this end, EFRAG’s work plan provides for numerous measures to actively involve various stakeholders. Particular attention is given to the experiences of those companies that already had to report for the 2024 financial year. By 6 May 2025, EFRAG had received several hundred responses and over 10,000 comments from affected companies. The public consultations on the revised drafts are scheduled to run until September 2025.

The Accounting Standards Committee of Germany (ASCG) has also approached EFRAG with specific suggestions in its comments of 15 April 2025 and 3 June 2025.

A summary of its main suggestions:

• Principles-based approach (“fair presentation”): Sustainability reporting should be more strongly principles-based. This means that reports should be based less on detailed provisions than general guiding principles. Companies should be able to decide themselves in their reports which information is material and appropriate to be able to give a realistic and comprehensive picture of sustainability aspects.
• Double materiality assessment (net instead of gross approach): Companies should be allowed to focus more on actual business risks in their reporting. In particular, companies should be allowed to apply a net perspective in their materiality assessment and also consider when they have implemented effective measures to reduce or mitigate negative impacts.

• Finance-based consolidated group as a benchmark: Under the current version of ESRS, it is possible for corporate entities to be included in sustainability reporting even though they are not part of the group consolidation according to financial reporting principles. For coherent and comparable reporting, it should be the same consolidation group as in financial reporting.
• Use of non-primary data, estimates and other measurement techniques: The use of such methods should be allowed not only along the value chain, but also within the company’s own operations. Estimates should no longer be limited to cases where metrics cannot be directly measured. If using estimates significantly reduces the data collection burden without compromising informational value, they should be permitted.

Other comments, such as those made by the Institute of Public Auditors in Germany (IDW) on 6 May 2025, likewise endorse significantly reducing reporting obligations through more precise requirements and the expanded use of estimates. In particular, the IDW highlights the heavy burden caused by interpretational ambiguities in the current version.

Conclusion and outlook

The revision of the ESRS fits into broader efforts to reduce the requirements of ESG reporting obligations. Companies should closely monitor the public consultation in late summer 2025 and actively engage in the process. The existing ESRS will continue to apply until EFRAG issues its final comments and the revisions are adopted by the European Commission.

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