Draft Simplified ESRS Unveiled
In early December 2025, following their formal approval by its Sustainability Reporting Board (SRB), EFRAG submitted the suite of draft simplified ESRS, essentially its technical advice, to the EC and publicly unveiled them at the EFRAG 2025 Conference. See the conference recording here and conference report here which summarises key points on the new simplified ESRS, as delivered to the European Commission, drawing on presentations by speakers and discussions during the panel sessions.
The full set of the draft simplified ESRS can be found here and at a glance factsheet here. On 9 December 2025 Position Green held a webinar on the simplified ESRS – access the recording here and slides here. This Corporate Disclosures article takes a closer look at the simplifications.
In less than six months EFRAG have significantly simplified the original ESRS. On many measures of size and burden the revised ESRS are less than half the original ESRS. At the same time EFRAG launched the ESRS Knowledge Hub, an interactive online platform to help users navigate the ESRS, including the VSME, and implementation materials developed by EFRAG.
In late December 2025 EFRAG announced the publication of the Basis for Conclusions, Cost–benefit analysis (CBA), and other documents to help stakeholders’ understand the draft simplified ESRS. The Basis for Conclusions explains how the feedback from the public consultation has shaped the amendments.
The CBA estimates that the draft simplified ESRS will cut reporting costs by 44% compared to the original ESRS. Large companies (10,000+ employees) could save around €1.1 million per annum while smaller companies stand to save around €150k annually. Competitiveness effects, which have been touted as a key objective of the simplification exercise, are assessed as neutral. Companies themselves do not seem to think that significant competitiveness effects are created through ESRS simplification. The study also acknowledges possible downsides from reduced information though acknowledges these may be partly offset by improved usability.
Reaction and Next Steps
Accountancy Europe has welcomed EFRAG’s technical advice on Draft Revised ESRS but in this public statement urges the EC to avoid further simplification and succumbing to political pressure so as to ensure stability in the EU sustainability reporting ecosystem. SMEunited has welcomed the formal adoption by the Council of the Omnibus I simplification package but stress that for SMEs, it is now a priority to adopt the VSME through a delegated act, ensuring they are not asked for more data points than what is included in the VSME.
The EC has already launched the consultation process on EFRAG’s technical advice. The EC must adopt the amended ESRS by way of a delegating act by mid-2026. The EC may decide to make targeted adjustments in response to concerns about the additional reliefs introduced by EFRAG. The EC is consulting with eight EU bodies identified in the Accounting Directive, which include the ECB, the EBA and ESMA. Once the EC submits the final text, the Parliament cannot amend individual provisions; it can only object to the delegated act as a whole. If neither the Parliament nor the Council objects during the scrutiny period, the delegated act automatically enters into force. DG FISMA oversees the process and the period for feedback ended on 6 February 2026.
While it seems unlikely the EC will simplify further, by reducing datapoints even more, the EC is expected to focus on reliefs. Some reliefs do not have time limits so opening the door for companies to defer some of the most challenging disclosures indefinitely. ESRS 1 paragraph 94 allows companies to omit information related to IROs, the value chain, metrics and anticipated financial effects due to undue cost or effort which is beyond the relief available under ISSB Standards. And ESRS 2 paragraph 29 allows companies to omit quantitative information on anticipated financial effects of material risks or opportunities if they do not have the skills, capabilities or resources to provide it. In effect, these provisions create permanent reliefs rather than transitional ones. During EFRAG’s drafting process, both the European Central Bank (ECB) and the European Banking Authority (EBA) expressed concern about these. The EC is also expected to decide on phase-ins for Wave 2 companies. The amended ESRS include an additional significant phase-in until 2029 for Wave 1 companies for the disclosure of quantitative information on financial effects and substances of concern, but EFRAG deferred the decision on phase-ins for Wave 2 companies to the EC.
The ECB staff have published their opinion on the revised ESRS which mirror Eurosif’s assessment of EFRAG’s final advice. The staff opinion express concern that the numerous permanent reliefs, phase-ins and exemptions granted to preparers risk limiting the availability and comparability of meaningful data and to increase divergence from other international reporting standards such as the ISSB. The ECB staff regret the changes to certain critical datapoints, some removed and some now volutary, and the need for sectoral guidance for financial institutions’ disclosures. And the ECB staff say that the VSME is not suitable for small and mid cap firms, and recommends using the revised ESRS instead.
Similarly the European Securities and Markets Authority (ESMA)'s verdict on the draft revised ESRS also expresses some reservations. ESMA finds the revised ESRS are only partly capable of meeting their objective of protecting investors and safeguarding financial stability and conclude by advising the EC to make adjustments including introducing time limits to certain permanent reliefs.
ESRS Datapoints
Sustainability Reporting Navigator, a team of German academics, have updated their ESRS Revision Impact Analysis to reflect the draft simpified ESRS handed to the EC. They find a 51% reduction in the number of mandatory data points, the impact being more pronounced for qualitative data points (58%) compared to a drop of 30% for quantitative data points. Of the data points retained in the revised ESRS, only 41% are legacy data points while the remaining 59% are new or amended data points, potentially triggering transition costs. Read the analysis here. The team have duly updated their ESRS revised datapoint list and provide the Excel sheet for free here and is editable.
Reflections of Retiring EFRAG SRB Chair
In this episode of Frankly Speaking (Youtube, Spotify and Apple) Richard Howitt spoke with Patrick de Cambourg, the outgoing chair of EFRAG SRB about the work of EFRAG, the ESRS simplification exercise conducted last year, and the future, amongst other things.
Research on Reporting Practices
A German study published on 5 February 2026 that examined over 750 Wave 1 CSRD reports found that in the first year of reporting under the ESRS only 16% of companies provided information on the anticipated financial effects of their environmental risks.
Findings from the annual 'Sustainability Transformation Monitor' of German businesses (n=688) provide the first glimpse of post-Omnibus I reporting (see full report in German here and an English summary here. The survey reveals 75% of companies that have fallen out of the mandatory scope of CSRD (that is ‘descoped’) plan to issue a voluntary report in the coming years. Of these 52% have already reported and plan to continue while 48% plan to issue their first report. The survey also shows that the Omnibus has slowed reporting processes and/or reduced ambition among both in-scope companies and larger descoped firms.
Sustainability Reporting Standards for SMEs
Since the European Commission officially adopted EFRAG’s Voluntary Sustainability Reporting Standard for non-listed Micro, Small, and Medium-sized Enterprises (VSME) as a Recommendation in late July 2025 EFRAG has been busy mobilizing implementation support (access the Commssion’s press release, Q&A, and the recommendation here and the standard, explainer videos, digital templates, and guidance on EFRAG’s website here.
Most recently, on 27 February 2026, EFRAG announced Dutch and Irish translations and Data Migration tool now available. The new free Data Migration tool enables seamless upgrades to the latest template version in just a few clicks. This provides more accessibility and fewer errors.
On 6 February 2026 EFRAG held the 2026 kick-off meeting of the SME Forum in which it presented its 2026 priorities along with the results of a survey into how to support VSME implementation at the national level. The meeting also included an introduction to the interactive VSME page on the ESRS Knowledge Hub, highlighting its functionalities and how it can support stakeholders in practice. Watch the recording here. EFRAG is planning a series of events for preparers, users and platforms in late February 2026, a VSME Community event on or around 13 March 2026 and second SME Forum meeting on or around 1 June 2026 - see EFRAG events schedule here.
In December 2025 EFRAG held an open session of the 3rd EFRAG SME Forum Meeting in which it presented three new supporting guides and shared insights from the first VSME Market Acceptance Report. The progress report reveals growing market awareness and takeup of the VSME as well as benefits in the shape of improved access to finance, cost optimisation and strategic advantages. The report also identified challenges including limited training, unclear methodologies and insufficient supporting tools as well as the lack of a centralised digital repository.
As explained here the report’s findings have prompted EFRAG to consider developing further practical guidance on specific disclosures, initiating a collection of practical examples of completed VSME reports to gather best practices, continuing work on the VSME Digital Template, and further mapping digital tools and platforms. EFRAG has already issued calls for expression of interest, with a deadline of 5 April 2026, for stakeholders to map digital platforms and tools such as GHG calculators. Read more here. In the near future EFRAG will launch a call for interest on collecting VSME reports (for organisations below 250 employees and those with 250–1,000 employees).
Omnibus VSME
The Omnibus outcome, rasing the threshold for mandatory reporting to 1,000 employees, has resulted in a much reduced CSRD scope. An additional 41,700 firms now fall under a voluntary regime. The Omnibus text states that the VSME is designed to both enable voluntary sustainability reporting by companies with fewer than 1,000 employees and limit the information that can be required from those companies in value chains. The voluntary reporting standard must be based on the VSME Recommendation in its original version. The EC is not likely to significantly revise it for companies with 250-1,000 employees. Rather the existing VSME will likely be renamed, maybe as the Voluntary ESRS (VESRS). Revised Article 29e envisages the launch of a dedicated portal that will include new templates and guidance suited to larger entoties. The EC must adopt the delegated act establishing the voluntary standards within four months of the Omnibus directive entering into force, that is by mid-2026, in concert with the adoption of the simplified ESRS.
Connectivity Discussion Paper
Late last year EFRAG released its Discussion Paper on Connectivity of Financial and Sustainability Reporting. Comments are due by 30 June 2026. Read more here.
ECG Guidance for CSRD Wave 2 Reporters
To support preparers of sustainability reports in the second year of reporting under the CSRD, the ECG has published a paper on some considerations for companies that can be accessed here.
Circular Economy
This Corporate Disclosures article examines how the newly simplified ESRS E5 aligns with the 2020 EU Circular Economy Action Plan (CEAP) policy framework. ESRS E5 sets out requirements for disclosing policies, actions, targets relating to resource use and the circular economy, and metrics on resource inflows and outflows.
EFRAG Updates
EFRAG’s Sustainability Reporting Update podcast and the Financial Reporting Update podcast are available on Spotify here. Read the updates in pdf here.
Belgian Awards for Sustainability Reports (BAS)
Following its award ceremony late last year the Belgian Awards for Sustainability Reports (BAS) has initiated a series of workshops ot help preparers. Register for and access the workshop slides and recordings here.
European Securities and Markets Authority (ESMA) ESRS Compliance Table
ESMA have
published a compliance table for the first years of application, highlighting that this is a learning period for companies, auditors, and authorities alike. With uneven transposition of the CSRD and the ongoing Omnibus revisions, the
Guidelines on Enforcement of Sustainability Information issued in April 2025 give national competent authorities (NCAs) the flexibility to focus on key priorities rather than minor errors, support issuers through dialogue and guidance, and reserve formal enforcement for serious or repeated issues.