The consultation was announced by EFRAG on April 8, 2025, and the deadline for participation is less than a month away, on May 6, 2025. The online consultation form is available at this address. EFRAG has also made it available in PDF format, if anyone would like to familiarize themselves with it before starting to fill it out.
Participating in the consultation can take anywhere from a few minutes to several hours. It depends on whether we only share general opinions on the application of ESRS standards or whether we want to submit detailed comments on each disclosure requirement. EFRAG hopes that this open approach will encourage not only the largest organizations, which can devote considerable time and resources to preparing responses, to participate in the consultation, but also smaller companies and individual experts, report preparers, users, and auditors.
Several sections in the questionnaire work in such a way that we have a drop-down list containing a number of items (e.g., several aspects of the double materiality principle or a list of all disclosure requirements). After selecting one of the items on this list, we can add our comment. Then we can add another field, select another item from the list, and add a comment to it, and so on. In this way, we can comment on one, several, or all of the selected items.
I strongly encourage you all to participate in the consultations. If you have just finished working on your first (or subsequent) ESRS-compliant report, you probably have a lot of comments on the specific disclosure requirements. If you have recently audited reports as a certified auditor, you know which elements of the standards companies have the most problems with. If you are just learning the standards, you are surely able to point out what is unclear or difficult about them. All of these voices are important!
If you don't have much time to participate in the consultation, please pay attention to at least two questions. The first is in section 2 (immediately after the header) and concerns general comments on the difficulties and benefits you see in applying the ESRS standards. The second interesting question is at the very end of section 2.1. and concerns those elements of the standards that you believe should remain unchanged. Although the aim of the entire revision of the standards is to simplify them, EFRAG should also receive clear indications from market representatives as to which elements of the ESRS should not be modified.
Once again, I invite you to devote either a moment, several dozen minutes, or a few hours to participate in the consultation. The deadline is May 6, but Easter and the May holidays are coming up, so there isn't much time left. It's worth speaking up, because the quality of future ESRS standards depends on all of us 😊
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