Sustainability Update: Why the Simplified ESRS is not an isolated framework

(28.01.26)

Insight on: ESRS & Interoperability

At a time when many companies are reassessing their sustainability reporting obligations, interoperability with existing EU regulation and global frameworks is becoming a key anchor for orientation and continuity.

In December 2025, EFRAG published an Explanatory Note under Article 29b of the CSRD, outlining how the Simplified ESRS aligns with EU legislation and international sustainability frameworks.

The key message of this publication:

-> ESRS is designed to connect - not to stand alone.

What does “interoperability” mean in the context of ESRS?

EFRAG’s note maps the Simplified ESRS against 18 EU and international frameworks, including:

• SFDR & EU Taxonomy
• TCFD & TNFD
• GRI & ISSB
• UN Guiding Principles, OECD Guidelines, ILO Conventions
• GHG Protocol

The key takeaway: 

-> ESRS builds on what many companies are already familiar with

Where alignment shows up in practice

A few examples from the Simplified ESRS:

• Climate (E1) & Biodiversity (E4) disclosures follow the well-known TCFD/TNFD structure, covering governance, strategy, risk management, and metrics & targets
• GHG accounting follows the GHG Protocol, using the same Scope 1, 2 and 3 concepts applied in most climate reporting frameworks
• Due diligence follows UNGPs and OECD logic, guiding companies to identify, prevent, and report negative impacts on people and the environment
• SFDR indicators are included in ESRS 2, linking reporting to EU sustainable finance requirements
• Taxonomy disclosures are structurally anchored in ESRS 1

For companies already reporting under other frameworks, this means: 

-> Less relearning, more continuity

Why this matters right now

With CSRD scope discussions ongoing, many companies are in a “wait and see” mode.

EFRAG’s message is reassuring:

✔ ESRS remains relevant beyond mandatory CSRD reporting

✔ It can support voluntary reporting

✔ It works as a common language across regulatory and investor-driven frameworks

In short: 

-> ESRS can act as a backbone - even when obligations change

Takeaway

The Simplified ESRS is not “just another standard”.

It’s a connecting layer in an increasingly complex reporting landscape.

Interoperability may well become the strongest argument for ESRS-based reporting - whether mandatory or voluntary.