CSRD : Introducing the simplified ESRS

From ESRS v1 to Simplified ESRS: Why You Don’t Need to Start from Scratch

Over the past two years, many European companies have invested significant time and resources in preparing their first CSRD report. With the publication of the simplified ESRS, a question comes up again and again:

“Do we need to redo everything?”

The short answer is: no.And that is exactly the point of this reform.

The simplified ESRS are not designed to invalidate previous work, but to build on it, streamline it, and make sustainability reporting more usable—both for companies and for report users.

Simplified ESRS

Why the ESRS Were Simplified

The European Commission and EFRAG received very clear feedback from companies, auditors, and stakeholders:

• Reporting had become too complex

• Many data points were redundant

• Some requirements added little value for decision-making

• Operational use of the standards was difficult

The result is a revised ESRS framework that:

• keeps the core logic of CSRD,

• removes unnecessary complexity,

• and focuses on decision-useful information.

What Has Not Changed

Before looking at what is new, it is important to be clear about what remains unchanged:

• Double materiality is still mandatory

• The objective of comparability over time and across companies remains

• CSRD is still meant to be a strategic risk and performance management tool, not a communication exercise

If you have already completed a double materiality assessment, you have already done at least 70% of the work.

Key Evolutions in the Simplified ESRS

1. Fewer data points, same structure

• The 12 ESRS standards remain

• But data points have been reduced by around 57%

• Focus is now on information that truly supports decision-making

2. Clearer structure and less repetition

• Transversal information is centralized in ESRS 2

• Thematic ESRS focus only on topic-specific disclosures

• Governance, policies, actions and targets are no longer repeated unnecessarily

3. More operational clarity

The revised ESRS clearly specify:

• what is expected,

• and just as importantly, what is not expected.

This reduces interpretation gaps and limits excessive auditor requirements.

4. A more pragmatic double materiality methodology

• A top-down sector-based approach is now allowed, in addition to the bottom-up analysis

• Obvious sector-wide material topics no longer require heavy justification

• Bottom-up analysis remains essential for company-specific risks and impacts

5. Introduction of the “relief” concept

• Replacing the former phasing logic

• Allows companies to progressively build reporting maturity

• Some disclosures may be omitted in year one and added later

How to Transition from ESRS v1 to the Simplified ESRS

The transition is not a rewrite. It is a methodical reorganization.

Step 1 – Start from your existing double materiality assessment

Your material topics remain your foundation.

Step 2 – Work topic by topic

For each material topic:

• identify disclosures that were removed,

• simplified,

• merged,

• or newly introduced.

Step 3 – Clean, move, and complete

• Remove what is no longer required

• Move transversal content to ESRS 2

• Add only what is genuinely new

Step 4 – Rewrite for coherence (not copy-paste)

Think of your first report as a set of building blocks:

• you already have the pieces,

• the simplified ESRS provide a clearer assembly guide.

The result should be a report that is:

• more readable,

• more coherent,

• and more useful for stakeholders.

A Tool for Strategy, Not Just Compliance

The philosophy of CSRD has not changed.

The simplified ESRS are designed to:

• reduce unnecessary reporting burden,

• while reinforcing the role of sustainability reporting as a strategic management and risk-pilotage tool.

For companies that have already started the journey, this evolution is not a setback — it is an opportunity to do better with less.