Sustainability Update: European Commission Draft on the Revision of the ESRS

Modified on Wed, 13 May at 10:56 PM

(13.05.26)


On 6 May 2026, the European Commission published the official consultation drafts (“Commission Drafts”) for the Simplified ESRS. These drafts build on the previously published EFRAG Simplified Drafts from November 2025, but include several additional targeted amendments and clarifications. The consultation period is currently open until 3 June 2026.

The overall direction remains unchanged:

  • significantly fewer mandatory datapoints
  • stronger focus on materiality
  • fewer narrative disclosures
  • greater proportionality and practicality
  • stronger alignment with ISSB/IFRS Sustainability Standards

The Commission itself refers to:

  • around 61% fewer mandatory datapoints
  • stronger prioritisation of quantitative information
  • clearer application of the materiality principle


What has changed compared to the EFRAG drafts from November 2025?

The Commission explicitly confirmed that it did not adopt the EFRAG draft on a 1:1 basis, but introduced targeted modifications. The most important changes relate to the following areas:


1. The materiality principle has been clarified and strengthened further

The Commission makes clear that non-material information should not be reported.

Before: “not required to report”
Now: “shall not report”


Practical implications

The Commission explicitly aims to reduce:

  • overreporting
  • unnecessary KPIs
  • excessively detailed reporting

In addition, it explicitly confirms that:

  • a top-down materiality approach is permitted
  • not every individual IRO has to be assessed separately


2. Fair Presentation has been clarified further

New in the Commission Draft

Fair Presentation applies:

  • to the sustainability statement as a whole
  • not to every individual datapoint

Implications

Less pressure regarding:

  • perfect completeness of every KPI
  • excessive audit documentation

More focus on:

  • overall understanding
  • material information
  • decision-useful disclosures


3. Aggregation / Disaggregation has become more flexible

New in the Commission Draft

The level of the materiality assessment does not automatically determine the reporting level.


Practical implications

Greater flexibility regarding:

  • regional disclosures
  • business unit disclosures
  • site-specific disclosures

Companies may aggregate information more broadly.


4. Anticipated Financial Effects have been significantly eased

New in the Commission Draft

The Commission clarifies that:

a) Estimates are permitted

Financial effects may be based on estimates.

b) Subsequent adjustments ≠ reporting error

Later adjustments due to new information do not automatically constitute a reporting error.

c) Sensitive information may be omitted

Where information would be commercially sensitive or seriously prejudicial.


Implications

Reduced liability and assurance risks in areas such as:

  • scenario analysis
  • forecasts
  • climate risk modelling
  • long-term financial estimations


5. Climate reporting (ESRS E1) has become more pragmatic

New

More flexible reporting boundary

Companies may apply either:

  • financial control
    OR
  • operational control

This further strengthens ISSB/IFRS compatibility.


In addition

If climate targets are not aligned with the 1.5°C objective, this must be disclosed transparently.


6. Human rights incidents have been narrowed

New

Only “substantiated incidents” must now be reported. This approach has been consistently integrated across S1, S2, S3 and S4.


Implications

No reporting obligation anymore for:

  • unsubstantiated allegations
  • unresolved complaints
  • non-substantiated cases


7. Pollution / microplastics disclosures have been simplified

New

Mandatory disclosures now only apply to:

  • primary microplastics

Secondary microplastics:

  • only in a significantly reduced / qualitative form


8. Additional targeted adjustments

Further additions and clarifications include:

  • stronger protection for sensitive information
  • new reliefs and phase-ins
  • stronger CSDDD alignment
  • simplifications for asset managers
  • greater flexibility regarding pollutants and SVHC


What happens next?

The final adoption of the simplified ESRS by the European Commission is currently expected already in July/August 2026, and at the latest by mid-September 2026. This will be followed by the formal scrutiny period by the European Parliament and the Council, which usually lasts two months. If no objections are raised, the revised ESRS will enter into force shortly after publication in the EU Official Journal and will apply directly across all EU Member States without national transposition. The revised standards will become mandatory from financial year 2027, while voluntary early application for FY2026 will already be possible.

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