ESRS Revision Progress Report

What You Need to Know About the Latest Updates to the ESRS

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On 19th June 2025, the European Financial Reporting Advisory Group (EFRAG) released a progress report on the revision of the European Sustainability Reporting Standards (ESRS). This marks a key step in the European Commission’s broader Omnibus Simplification Package, which aims to reduce the regulatory and administrative burden of key sustainability regulations, while still upholding the ambitions of the EU Green Deal.

As a member of Friends of EFRAG, Anthesis contributed to this process through the consultation phase and welcomes the direction of travel in these proposed changes.

While not yet final, the progress report outlines a draft of what a revised, simplified ESRS could look like, targeted at making sustainability reporting less burdensome, more strategic, and more aligned with global frameworks. A second draft is expected in early July, with the final technical guidance due to the European Commission by 31st October 2025.

How does this fit within the broader CSRD changes?

These proposed ESRS revisions are one component of the EU Omnibus Simplification Package released in February 2025 and updated in June 2025, focusing on what needs to be disclosed under the ESRS standards.

While the widely discussed ‘stop the clock’ amendment pushed back reporting deadlines for many companies, other regulatory elements, such as who is in scope and how reporting should be conducted, remain at the proposal stage.

The EU Council released a new proposal on 21st June 2025 that aligns with EFRAG’s efforts to streamline ESRS disclosures by removing data points, clarifying which disclosures are mandatory, and emphasising the importance of interoperability between the ESRS and ISSB standards.

Find out more about the Omnibus Package here

What does the progress report tell us?

The draft can be summarised into four key areas of simplification:

EFRAG acknowledges that current requirements for double materiality are resource-intensive and risk becoming a box-ticking exercise rather than a strategic assessment of the impacts, risks and opportunities relevant to an organisation’s unique business model.

The revised approach aims to:

  • Prioritise an organisation’s business model to support the identification of material topics
  • Avoid requiring full disclosure on a topic where only a sub-topic is deemed material
  • Clarify how mitigation should be considered when assessing material impacts
  • Focus assessments on information that is relevant and decision-useful, not exhaustive
  • Emphasise a proportionate and evidence-based process

The revised changes should help organisations generate insights that are more relevant to their unique business models and value chains, strengthening double materiality as a foundational step in identifying what matters most. This clarity supports the implementation of more targeted and effective sustainability practices and enables more meaningful and aligned reporting under CSRD.

The report acknowledges that a lack of clarification around how flexible preparers can be with the report template has led to organisations finding it difficult to tell their unique sustainability story, and an increasing focus on CSRD as a compliance exercise.

To support more coherent and impactful reporting:

  • Organisations will be able to include an executive summary
  • Detailed disclosures can be moved to appendices to enhance readability
  • Disclosure will be limited to material matters, with clearer distinctions between mandatory and non-mandatory requirements
  • Guidance will be provided on the flexibility of reports to avoid duplication of information to suit a rigid report template, helping companies tell their sustainability story more effectively

 

In line with the aim to simplify reporting, EFRAG recommend a significant reduction in the required data points, achieved by:

  • Better aligning the requirements between the two cross-cutting (ESRS 1 & 2) and the ten topical ESRS standards to reduce duplication
  • Removing non-essential data points (both qualitative and quantitative), but with a retained focus on quantitative data points
  • Clarifying which disclosures are mandatory

 

Another key area is the focus on achieving greater interoperability with other standards, with priority given to alignment with the IFRS’ International Sustainability Standards Board (ISSB) S1 and S2 standards. This includes aligning reporting boundaries and language across the standards.

 

What this means: A strategic step forward for double materiality

At Anthesis, we welcome these proposed simplifications, particularly the emphasis on positioning the double materiality process as a strategic tool rather than a compliance hurdle. This aligns closely with our established approach and the feedback we shared through the consultation process.

We’ve heard from many large organisations, whose assessments were led by providers without deep ESG knowledge, that the double materiality process was not robust enough compared to other risk management processes and the impacts, risks and opportunities identified felt too generic or disconnected from their actual business or sector context. This creates challenges for developing strategies to address them and leaves a gap between what is reported and what needs to be managed.

Done right, double materiality should enable companies to reflect the unique characteristics of their value chain, prioritise what’s most material to their business, and drive long-term, measurable value.

Our double materiality assessments are grounded in strong ESG expertise and a deep understanding of business strategy, enabling us to deliver insights that are both tailored and decision-useful.

What should you do now? 

While this draft is subject to change, the direction of travel is clear, and simplification will happen.

For organisations entering Year 2 of CSRD reporting, there may be limited opportunity to respond to the proposed simplification in your next report. But you can already align with its intent by ensuring you have developed strategies to manage your Impacts, Risks, and Opportunities (IROs) and that you are clearly reporting on how they align with the actions you’re taking, the metrics and KPIs you’re using, and your performance. We recommend getting started as soon as possible to prioritise materiality, reduce duplication, and streamline your narrative.

For companies with a two-year delay, there is time to prepare but plenty to do ahead of the deadline. If you haven’t already, we recommend starting your double materiality assessment now, using these draft revisions as a guide. Doing so gives you time to collect data, close gaps, and shape an integrated sustainability strategy ahead of the FY2027 deadline.

Organisations that have already finalised their Double Materiality Assessment should begin preparing for a gap analysis focused on at least three core ESRS: E1 (Climate), S1 (Own Workforce), and G1 (Business Conduct). Analysis of existing reports from Wave 1 companies shows that all reported on these three standards, making them a logical and low-risk starting point. By concentrating on the mandatory quantitative disclosures within these ESRS, companies can gain time, maintain momentum, and avoid over-engineering early-stage reporting efforts. You may also choose to extend this approach to other clearly material topics, applying the same focused methodology.

Although the reporting deadline has been pushed back, using this time to make continuous improvements will enable more mature and robust disclosures by 2028. With a realistic roadmap and clear alignment from top management, you’ll be in a stronger position to secure the necessary budget and cross-functional time commitments, especially as ESG managers cannot deliver this alone.

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How Anthesis can help

At Anthesis, we help clients go beyond compliance to unlock the full value of sustainability reporting.

Our approach ensures your CSRD disclosures:

  • Reflect your unique risks and opportunities
  • Are decision-useful for internal and external stakeholders
  • Support governance, performance, and long-term impact

With 1,400+ sustainability experts across climate, human rights, supply chain, finance, and beyond, we bring deep technical know-how, regulatory insight, and a proven ability to implement change.

Whether you’re starting your CSRD journey or preparing your second report, we can help you bridge the gap between materiality and action.

Book a call here

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