The conference on 5 May 2026 was attended by over 100 representatives of Polish companies, both listed and private, both those reporting on a mandatory basis and those who, as a result of the Omnibus, are outside the mandatory scope but have either already decided to report voluntarily or are in the process of making that decision. The conference was organised by Frank Bold in substantive partnership with MATERIALITY, under the patronage of the Polish Association of Listed Companies (SEG), POLSIF and Responsible Business Forum.
Representatives of these three organisations joined Bartosz Kwiatkowski in a panel discussion on the changes in EU policies aimed at strengthening the EU's security and building the competitive advantages of European companies. Joanna Ałasa spoke about sustainable finance opportunities, Mirosław Kachniewski about tools the Commission could use to ease the operating environment for companies, and Robert Adamczyk, in addition to highlighting global sustainability trends, reminded us of the fundamental values we care about: democracy, freedom, and the right to live in a healthy environment.
For the next hour and a half, Filip Gregor and I talked about what has changed in ESRS. Common-sense materiality testing, much greater flexibility in shaping the structure and content of the report, the overarching principle of fair presentation, and numerous facilitators were just some of the topics we discussed. Some of the standards discussions moved to the backstage, as the conference was probably the first event in Poland where as many as three ESRS co-authors were present at the same time (Filip is a member of the EFRAG Sustainability Reporting Board, and Robert is active in TEG's SR along with me).
The public consultation on draft delegated regulations introducing the simplified ESRS and VS, announced by the Commission the following day, will run until 3 June 2026. Please take part! Although I have not yet analysed the Commission's changes in great detail, I can already say that I will personally have relatively few comments.
The Commission's draft ESRS departs only marginally from what EFRAG presented at the turn of November and December 2025. And that is a very good thing! It means the Commission has resisted the powerful lobbying conducted by the IFRS Foundation over the past several months. The double materiality assessment remains the foundation of reporting. The IFRS Foundation had wanted companies to produce, in effect, two reports: one directly meeting the requirements of its standards, based on risks and opportunities, which could then be accompanied by a second report addressing impact materiality. A wonderful simplification proposal: two reports instead of one 😉 Fortunately, nothing of the sort will happen.
Among the more significant changes introduced by the Commission, I would mention that GHG emissions reporting will fully utilise the possibilities provided by the GHG Protocol, meaning a company will be able to independently decide which consolidation approach to adopt. In addition, the Commission has made it entirely unambiguous that a report must not contain immaterial information. EFRAG, in relation to immaterial information, had proposed the wording "is not required to disclose," whereas the Commission strengthened this to "shall not disclose." This measure is intended to provide additional protection for companies against the expectations of certain advisers and auditors who, when in doubt, recommended disclosing something anyway (even if not quite material) on the basis that more is better. Well, quite the contrary, more is not better, and only material information should appear in the report.
Beyond the minor but largely positive changes to the draft standards, the Commission has included in the draft delegated regulation itself a provision that many have been anticipating: companies will be able to use the simplified ESRS starting with their reporting for the year 2026. I encourage you to do so, because the new standards are genuinely much simpler than the old ones 😊
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