Our Response to EFRAG's Consultation on ESRS Amendments

At the end of July 2025, EFRAG published its proposals to simplify the ESRS standards, providing for a 57% reduction in mandatory data points to be disclosed.
Posted on
Nov 26, 2025

Our Response to EFRAG's Consultation on ESRS Amendments

At the end of July 2025, EFRAG published its proposals to simplify the ESRS standards, providing for a 57% reduction in mandatory data points to be disclosed. This reduction is part of the Omnibus directive aimed at simplifying CSRD requirements. From July 31 to September 29, 2025, EFRAG submitted these 12 amended ESRS for consultation, in which WeeFin participated. Discover our perspective on these modifications in this article.

ESRS Facing the Simplification Challenge: A Strategic Turning Point

Since the entry into force of the CSRD directive, European companies have had to meet new sustainability reporting obligations. The ESRS (European Sustainability Reporting Standards) were developed to harmonize non-financial reporting practices at the European level. The simplification of CSRD and these ESRS was initiated by the adoption, in February 2025, of the Omnibus I package aimed at easing certain reporting requirements and modifying the compliance timeline. It is in this context that EFRAG presented the 12 amended ESRS last July.

Key Figures of the Proposed Simplification:

  • 57% reduction in mandatory data points
  • 68% decrease in the total number of indicators (including voluntary indicators)
  • Increased flexibility: only information considered material to the company must be reported

These modifications aim to make reporting more accessible while maintaining the European Union's ambition for transparency.

WeeFin's Position: Pragmatism and Regulatory Coherence

In our response to the consultation, WeeFin defended five principles to ensure the effectiveness of the simplified ESRS:

1. Opposition to Excessive Reduction of Reporting Requirements

We express our disagreement with an overly significant reduction in mandatory data points. While apparently favorable in the short term for companies, this reduction represents an obstacle to the following improvements:

Resilience to ESG Risks

Reporting on all material metrics enables companies to secure their financing and implement measures to strengthen their resilience to ESG risks. This approach is particularly crucial given the rapid increase in physical risks, with significant changes expected as early as 2030. Proactive engagement now is essential to ensure this resilience, especially as insurers will scrutinize and hold companies accountable for their risk management.

Data and Communication Mastery

The first reports published since 2025 demonstrate the feasibility and usefulness of CSRD for companies, as well as its necessity for the economy. Companies that disclose more maintain better control over their communication and strategic plans. Moreover, these reported data points would improve the quantity and quality of ESG data available on the European market for all stakeholders.

European Competitiveness

Many international financial players already comply with European standards such as SFDR and remain attracted by the appeal of the European market despite these additional requirements. While non-financial reporting may seem constraining for the competitiveness of European companies, the reporting obligation for non-European companies must be maintained.

2. Preservation of Double Materiality

Double materiality remains at the heart of the ESRS framework. WeeFin emphasizes the importance of maintaining this approach, which analyzes both companies' impacts on society and the environment, and ESG risks weighing on their financial performance.

We also highlight the need to maintain a certain level of justification for DMA topics deemed immaterial to ensure the standard's transparency.

3. Harmonization with International Standards

Several changes have been introduced to strengthen the harmonization of ESRS with ISSB's IFRS S1 and S2 standards. WeeFin supports this harmonization, which helps avoid regulatory fragmentation and facilitates multi-jurisdictional reporting.

4. Improvement of Data Governance

The reliability of ESG disclosures depends on the robustness of data governance frameworks. WeeFin recommends clear requirements on:

  • Data traceability and source documentation
  • Validation processes and auditability mechanisms
  • Use of quality indicators (primary data, PCAF methodology, uncertainty percentages)

5. Transparency on Methodological Limitations

Rather than an exception to report when precise quantitative data is inaccessible, WeeFin supports a balanced approach where companies can use estimates or proxies. This flexibility is accompanied by rigorous transparency requirements:

  • Companies must clearly document and communicate the limitations of their methodologies
  • A data coverage rate must be published to precisely indicate covered and non-covered scopes
  • Standardized estimation methodologies should be proposed to ensure comparability between entities

This approach helps avoid biases in reported data while recognizing the practical challenges of data collection. Moreover, this information is also crucial for investors who must themselves comply with reporting obligations, particularly under SFDR.

Timeline and Next Steps

  • November 30, 2025: Submission of EFRAG's final technical advice to the European Commission
  • Early 2026: Expected publication of simplified ESRS
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