On 6 May 2026, the European Commission launched a consultation on the ESRS. The amendments to the ESRS have been proposed to simplify and streamline European sustainability reporting without undermining the objectives of the Corporate Sustainability Reporting Directive (“CSRD”).

Amendments to the European Sustainability Reporting Standards were originally proposed together with the Omnibus I simplification package in 2025, with the intention to simplify and streamline the Standards without undermining the objectives of the CSRD.

EFRAG (the body appointed to prepare the ESRS) carried out consultations and stakeholder meetings during 2025, and issued its recommended simplified version of the ESRS to the Commission in November 2025. The European Commission has since conducted its own consultations with official groups and stakeholders and has now published their revised version of the ESRS.

The ESRS have now been used by a number of undertakings reporting for both mandatory and voluntary purposes and feedback has been gathered by both EFRAG and the Commission. The revised ESRS are intended to take this wealth of experience and (i) clarify existing ESRS provisions which are deemed unclear; (ii) simplify the structure and presentation of the Standards and (iii) take into account the difficulties undertakings might encounter when gathering relevant data especially from actors in their supply chain not subject to CSRD.

The Commission has made a number of targeted modifications to EFRAG’s November technical advice “with the primary aim of facilitating the application of the standards by clarifying certain provisions and granting certain additional flexibilities to undertakings”.

The Commission’s modifications address the following areas:

• Materiality and materiality assessment.
  • The revised text states that undertakings do not need to meet the specific information needs of each individual user: the objective of the standard is that reporting should be decision-useful for users.
  • A clear definition of the concept of “informed assessment “ is introduced.
  • It is specified that “undertakings “shall not” report information that is not material, except in certain clearly defined circumstances, rather than stating that the undertaking “is not required to” report information that is not material.
  • A new provision emphasises a “top-down” approach to materiality assessment to avoid unnecessary work and avoid assessing individual impact, risk or opportunity.
• Fair presentation.
  • The text clarifies that fair presentation applies to the overall sustainability statement and not each data point.
  • It states more clearly that application of ESRS themselves achieves fair presentation and that the modifications to materiality and materiality assessment will facilitate the application of the principle of fair presentation.
• Level of aggregation and disaggregation.
  • The revised text provides greater discretion to the undertaking regarding specific geographical contexts when carrying out materiality assessments.
  • It is clarified that the level of disaggregation for materiality assessment purposes does not imply that information should be reported at the same level of disaggregation.
• Omission of information. As foreshadowed by the Omnibus I simplification, undertakings will be able to omit certain information in certain circumstances, including information that could be seriously prejudicial to the commercial position of the undertaking.
• Anticipated financial effects.
  • The revised text recognises that reporting anticipated financial effects is likely to involve estimates and that these can be updated in the future in light of new information without this constituting a reporting “error”.
  • It also clarifies that the provisions that allow undertakings to omit certain information in certain circumstances also apply to reporting on anticipated financial effects.
• Greenhouse gas emissions. The revised text aligns more closely with global sustainability reporting standards; giving undertakings the flexibility to use either the financial control approach or the operational control approach when defining the reporting boundary to be applied.
• Climate transition plans. Undertakings that report transition plans with targets that are not compatible with 1.5°C target need to be transparent about this.
• Microplastics. Disclosure is limited to primary microplastics, reporting on secondary microplastics is not required due to feasibility and proportionality reasons.
• Emission of pollutants. The decision as to which pollutants are material for reporting purposes should be taken following a managerial assessment that considers the undertaking’s activities and sector of operation.
• Substances of very high concern. A new one year phase-in provision has been introduced for reporting on substances of very high concern for undertakings that are users of articles containing such substances.
• Coherence with CSDDD. The text includes a number of technical modifications regarding due diligence to ensure better alignment with the Corporate Sustainability Due Diligence Directive (“CSDDD”).
• Human rights incidents and incidents of discrimination.
  • Only “substantiated” instances need to be reported (and not all instances are necessarily substantiated instances).
  • The revised text also refers to “ongoing” judicial and non-judicial proceedings rather than to proceedings that have been “initiated”.
• Asset management activities. The proposed text includes new provisions to avoid the risk that undertakings that carry out asset management activities are required to report information that is not relevant about the investments that they manage.

Although recent press reports suggested that the Commission was considering structural changes to the ESRS to separate financially material and impact material information to facilitate alignment with the the International Sustainbaility Standards Board (“ISSB”) Standards, these measures do not appear to have been included in the revised ESRS.

The period for feedback on the revised ESRS runs until 3 June 2026 and participants are invited to respond (including on an anonymous basis) via the dedicated consultation webpage here. The Commission has stated that it plans to adopt a final version of the amended ESRS in the course of 2026, such that the final amended ESRS could apply to financial years beginning on or after 1 January 2027 (i.e. for reporting in 2028).

Interestingly, the Commission has also stated that wave one undertakings could choose to apply the final amended ESRS for financial years beginning between 1 January 2026 and 31 December 2026 (i.e. for reporting in 2027).