Simplified ESRSs published by EFRAG

December 8, 2025
Piotr Biernacki
Sustainability Managing Partner
On December 3, 2025, EFRAG submitted simplified ESRS standards to the European Commission and published them. What happens next? When will we be able to use them? Which companies will be required to apply them, and which will do so voluntarily? What state of sustainability reporting can we expect in 2026 and beyond?

All interested parties have probably already reviewed the final versions of the standards, but for the sake of clarity, I would like to remind you that The entire set is available on this EFRAG website.. In turn Here you will find a recording of the conference held on December 4, 2025., during which the standards were presented and discussed. Over the next two weeks or so, EFRAG will publish Basis for Conclusions (i.e., a detailed justification for each change made to the standards) and Cost-benefit analysis (cost-benefit analysis of introducing simplified ESRS). For those interested in reporting, both materials will probably be even more interesting than the standards themselves...

The European Commission has already launched a complex procedure to prepare, on the basis of the standards provided by EFRAG, a delegated regulation that will implement them. This includes internal consultations with various directorates-general and a number of EU institutions. Interestingly, Commissioner Albuquerque made no mention of public consultations on Thursday. Usually, draft delegated regulations are submitted for 30 or 60 days of public consultation, but this time the Commission may decide not to do so, as EFRAG has already conducted two rounds of consultation (in April and August-September 2025). The delegated regulation will be issued in such a way that the standards will be mandatory from 2027 (reports for 2027 published in 2028). In addition, it is possible that the option to choose between „old” or „new” ESRSs will be introduced for the 2026 report. I expect the regulation with the new standards to be issued in June or early July 2026.

The new, simplified ESRS will be mandatory for companies that remain within the scope of the CSRD. We will find out which ones these are after the trilogues on the Omnibus are completed, i.e. in the coming weeks. Most likely, in Poland, the obligation will apply to several dozen companies; perhaps more than 100, if many of them do not take advantage of the exemption available to subsidiaries.

And voluntarily? Any company will be able to use simplified standards voluntarily, although I do not expect small and medium-sized enterprises to use them. VSME has been developed for them. Some large companies may also consider using these guidelines, although they are not accounting standards, were not designed for large companies, and will not fulfill their purpose. I would like to be understood correctly: VSME is a great set of guidelines for micro, small, and medium-sized companies, but it is simply not suitable for large entities.

Companies that decide to report voluntarily will have more than just the new ESRS to choose from. I predict a renaissance of GRI standards. There are two sources for this: in Europe, it is Omnibus and a significant reduction in ESRS, and globally, the rapid growth in the importance of sustainability reporting, primarily in Asia (with China, of course, playing a dominant role, where GRI standards are already used by 2,500 companies). The IFRS S1-S2 standards, which are being adopted as mandatory in more and more countries, will also gradually become increasingly important.

To what extent will we report using simplified ESRS in Europe, and to what extent will we turn to GRI and IFRS or a combination of the two? We will see, as this will depend on a number of factors, such as the expectations of financial institutions and business partners, as well as market practice. The publication of guidelines or a standard for the certification of reports by the Commission will also be significant. In Poland, I am curious about the work on the revision of KSUA 3002PL. For obvious reasons, this standard is not adapted to simplified ESRSs. I hope that during the review, elements of goldplating will be removed from it, which currently make certification closer to reasonable than limited assurance.

All this concerns the future, but in the meantime, we have a reporting season ahead of us using the „old” ESRSs. And reading the „new” ones, which are much simpler and finally give us the opportunity to tell a concise story about the company and its sustainable transformation in 20, 30, or 40 pages, instead of boringly „ticking off” successive data points that the auditor asks us about 😉

Share

Let's stay in touch

These articles you may be interested in

There has been a great deal of activity in the last year regarding changes in sustainability reporting obligations. This has taken place
Sonia Kortas
09 Feb 2026
In the era of the fourth industrial revolution, our approach to technology is becoming the foundation of ESG strategy. We are taking an active part in consultations and
03 Feb 2026
In January, many organizations and individuals published their predictions for how sustainability will change in 2026.
Piotr Biernacki
02 Feb 2026