Implementation schedule and context of the simplification work
Work on simplifying ESRS standards was initiated by the European Commission in March 2025 as part of the legislative initiative Omnibus, aimed at deregulating and reducing the administrative burden of the CSRD. EFRAG (the European institution that creates and provides opinions on financial and sustainability reporting standards for the European Commission) completed work on the drafts in November/December 2025, submitting the final versions to the European Commission.
The European Commission plans to issue a new delegated regulation in the summer - as early as June 2026. Full application of the new standards is anticipated starting in the fiscal year 2027, but the regulations provide for transition periods:
- Mandatory reporting companies: For 2025 (reported in 2026), they must use the „old” set of 2023 standards. In the 2026 report (published in 2027), they will be able to choose between the old and new standards. From 2027, only the new, simplified set will apply.
- Companies reporting voluntarily: They can choose the simplified ESRS as early as 2025 reporting. As with mandatory reporting, starting in 2027, the simplified standards will become the only set available to them under the ESRS.
Details of the projects can be found on the official website EFRAG - Draft Simplified ESRS.
Load Reduction: 70% fewer data points
The most visible change is a radical slimming down of standards. Mainly raised is the number of data points (data points), which has dropped from more than 1,000 in the first set to just over 300. This represents a reduction of approximately 71%. This data is impressive, but it essentially ignores the difference in the complexity of the individual data (it's hard to compare a simple policy description with a full calculation of Scope 3 emissions). Much more strongly on us - practitioners - the
A comparison of the volume of the documents themselves works: the number of pages has more than halved - from 300 to about 130.
What has disappeared from the standards?
Key to achieving these savings was the removal of all voluntary data points (so-called „may disclose”) and a reduction of more than 60% Mandatory points („shall disclose”). However, it is worth remembering that the thematic scope has remained unchanged - we are still operating within the framework of 12 standards: two cross-cutting ones (ESRS 1 and 2) and ten thematic ones.
New Rules of the Game: Fair Presentation and Undue Cost or Effort
The simplified ESRS standards introduce two fundamental principles to make life easier for report preparers:
- The principle of fair presentation (Fair Presentation): It is becoming an overarching reporting principle. This means that the report is supposed to faithfully reflect the company's material impacts, risks and opportunities (IROs), and not just be a completed checklist or a rigid table.
More specifically, the principle of fair presentation explains Piotr Biernacki during the training „Simplified ESRS Standards”.”
- Undue Cost or Effort principle: If the acquisition of data (especially from the value chain) involves an expense that is disproportionate to the benefits for the users of the report, the company may refrain from disclosing it, justifying this decision. The exception to this rule remains data on greenhouse gas emissions (E1-8).
- Additionally, materiality testing (materiality assessment) is becoming more pragmatic.
We write more about the significance testing process in the description of the consulting on materiality testing. At MATERIALITY, we have developed our own research methodology based on industry documents and best practices, already applied in dozens of projects for companies in many industries. We are constantly updating it and adapting it to our clients.
Strategic changes in the structure of the report
The new standards focus on flexibility and transparency. Key new features include:
- Executive Summary: Ability to create a concise management summary.
- Attachments: Moving detailed descriptions of methodologies or data tables to annexes, which improves the readability of the main part of the document.
- Integration of guidelines: Application Requirements are now located directly under Disclosure Requirements, eliminating the need to constantly jump between sections of the document.
Reduction is not everything
All the described changes affect the overall perception and readability of the document. Not only has the volume and layout of the content changed. Another favorable change in the ESRS is the simplified language. The deep editing of the text of the standards, the rearrangement of footnotes, the clarification and unification of definitions make the whole reads more smoothly and it is easier to understand the document.
Controversy over VSME and important ECB opinion
An important element in the debate about simplified ESRS standards is their applicability to companies not directly subject to CSRD reporting. Although parallel standards are available VSME (Voluntary Sustainability Reporting Standard -. for small and medium-sized enterprises), there have been significant criticisms.
February 11, 2026 European Central Bank (ECB) in its official opinion forwarded to the European Commission indicated that it was Simplified ESRSs should be the recommended standard for large companies outside the CSRD to use voluntarily. According to the ECB, the VSME standard is not adequate for large entities and does not meet the information needs of the financial sector to the extent that the simplified ESRS does. This sends a clear signal to large groups that want to report voluntarily to direct their attention specifically to this set of guidelines.
Summary: Will reporting get easier?
A cost-benefit analysis commissioned by EFRAG shows that the use of simplified standards will be even by 30-40% cheaper than the existing set. Although the role of company-specific disclosures (which requires more creativity and exploration of standards such as GRI or SASB), the overall balance of change is definitely favorable.
The transition to the new standards for companies that already report should be smooth, as most quantitative metrics remain similar. For new entrants, the simplified ESRS provides the most complete and understandable „playbook” for implementing sustainability reporting.
Want to prepare your organization for upcoming changes in standards?
We have specially prepared a preliminary ESRS simplified standards training. Join our course on MATERIALITY ACADEMY and see other resources in the knowledge and practice at materiality.pl.
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