The entire consultation package is available on the EFRAG website at this address. In it, you will find:
- ESRS 1 and 2 cross-cutting standards and 10 thematic standards. In each case, a file with the new content of the standard is available and Log of Amendments, i.e., a document in which, paragraph by paragraph, the content of the current and new versions of the standard is compared, along with an explanation of the reasons for the changes.
- Annex II to the delegated regulation, i.e., a set of all definitions used in the standards (available in a „clean” version and with a comparison of changes relative to the currently applicable annex).
- NMIG, or Non-Mandatory Implementation Guidance. These are guidelines that were previously part of the standards (usually found within the Application Requirements). The status of NMIG is not yet known. These guidelines may be issued by the European Commission or by EFRAG.
- Basis for Conclusions, a document explaining in detail the changes made, the reasons for them, and the entire process that led to these changes.
- Other documents, such as press releases, FAQs, consultation forms in PDF format, summaries of information obtained from stakeholders, etc.
I suggest starting with Basis for Conclusions. This document will give you the quickest overview of the main changes introduced in the standards. It will allow you to form a general opinion about the possible effects of the changes on companies, but also on the recipients of the information contained in the reports. And then, of course, I encourage you to read the drafts themselves carefully 😊
The consultation will run until September 29, 2025, and will be conducted via an online questionnaire available at this address. Before you start filling it out, it is worth reading the PDF version of the questionnaire. It is divided into three main parts:
- Information about the person participating in the consultation
- General feedback on the draft standards (a series of questions – you can answer all or only selected ones)
- Detailed feedback on the draft standards (here you can comment on specific disclosure requirements and paragraphs)
If you are a member of the Polish Association of Listed Companies, I encourage you to participate in webinar on September 3, 2025., during which the proposed changes will be discussed in detail.
Is it worth spending time participating in consultations? If I ask this question, it is obviously rhetorical 😉 Of course it is worth it! If you are involved in preparing sustainability reports, certifying them, or reading reports to obtain information from them, now is the time to influence the future shape of standards.
We are no longer at the stage of complaining about what was difficult or incomprehensible in the ESRS. We have moved on to the stage where we have a draft of their new content before us and it is worth assessing whether the changes are appropriate. Some things could probably be simplified further. Perhaps some changes have gone too far (as you know, I think this is the case with a few points, especially in ESRS 1). Or maybe something should be defined or described differently?
All the work that the Sustainability Reporting TEG and Board will be doing in the fall to prepare the final draft for the European Commission will be based on the results of the public consultation. That is why I warmly encourage you to participate in it 😊
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