Simplified ESRS: What Is Changing and What Companies Should Do Now

The Simplified ESRS

The ESRS (European Sustainability Reporting Standards) are set to become simpler, but not less important. With the planned Simplified ESRS, also referred to as Amended ESRS or ESRS Set 2, the focus is shifting: away from maximum detail and toward sustainability reporting that presents material topics more clearly, more consistently, and in a more practical way. For companies, this raises not only the question of what will be removed in the future. More importantly, it is about what will actually matter in reporting going forward.

The planned changes are linked to the EU’s Omnibus initiative. The aim is to streamline sustainability reporting requirements under the CSRD (Corporate Sustainability Reporting Directive) without abandoning the core logic of the ESRS. For companies, this means fewer mandatory disclosures, but still a clear focus on material information, transparent disclosures, and a robust presentation of their sustainability topics.

At a glance: What the Simplified ESRS mean for you now

Already deep into ESRS? → Map existing data points to the Simplified ESRS instead of starting from scratch.

Just getting started? → Clarify early whether VSME, Simplified ESRS, or another reporting framework is a better fit, then set up data collection directly along that logic.

No longer in scope? → Assess which form of voluntary reporting makes strategic sense.

Still have time until 2028? → Use the additional time to align materiality, data architecture, and responsibilities cleanly with the Simplified ESRS.

Where do the Simplified ESRS currently stand and what can be expected next?

The Simplified ESRS have not yet been formally adopted. So far, EFRAG’s technical recommendation to the European Commission is available. The final version of future ESRS Set 2 still needs to be adopted by the Commission as a delegated act.

Since the EU plans to adopt EFRAG’s draft as it stands, the direction is already clear: fewer data points, fewer redundancies, greater focus on material information, and more principles-based reporting.

For companies, the draft status is therefore not a reason to wait. Those who understand the logic behind the Simplified ESRS now can already begin aligning reporting processes more effectively toward relevance, coherence, and practical data use.

What is new?

Focus on material information

Going forward, only material data points are expected to be disclosed. The goal is a sustainability report that is clearer and less driven by formally checking off every single requirement wherever possible.

Significantly fewer data points

According to EFRAG, mandatory data points are expected to be reduced by around 61 percent. At the same time, voluntary disclosures will be removed. So this is not just about less volume, but also about stronger focus on what is truly relevant for users and decision-making.

Shorter and more understandable standards

The standards are expected to be streamlined. Redundant content will be cut back, and overlaps between ESRS 2 and the topical standards will be reduced. This is intended to improve readability and make application easier in practice.

More principles-based narrative reporting

Key governance topics such as SBM-3, IRO-1, as well as Policies, Actions and Targets will be brought together more strongly. At the same time, presentation is expected to become more flexible. As a result, the report should function less like a checklist and more like a coherent overall picture.

Less burden around value chain data

Going forward, there will no longer be an explicit preference for primary data. Estimates and secondary data are also expected to be allowed where robust primary data is unavailable or can only be obtained with disproportionate effort.

Simplified materiality assessment and clearer disclosure logic

Disclosure logic is also becoming more focused. Companies should be better able to distinguish between material and non-material information. This also affects the question of which mandatory disclosures are actually required and where narrative context matters more than completeness for its own sake.

What stays the same?

Despite the simplification, the core logic of the ESRS remains in place. ESRS Set 1 is not being reinvented, but rather condensed, focused, and further developed in the form of the Simplified ESRS. The double materiality assessment (DMA) also remains a central starting point for reporting. The following three points will continue to be central in the new Set 2:

Double materiality remains mandatory.

Companies must therefore continue to systematically assess which sustainability topics are material, both from an impact perspective and a financial perspective. What is new is mainly that application is intended to become more practical: EFRAG refers to clearer guidance, less documentation effort, and stronger focus on truly decision-useful information.

The 12 topical standards remain structurally in place.

The Simplified ESRS continue to build on the same architecture: ESRS 1 and ESRS 2, along with the familiar environmental, social, and governance standards, remain in place. For companies, this means existing structures, responsibilities, and mapping logic can generally continue to be used, while the depth and volume of required disclosures will be reduced in many places.

The objective remains a transparent presentation of material sustainability topics.

Even with simplified requirements, companies are not expected to simply check off data points, but to explain clearly which material topics they have identified and how they manage them. EFRAG emphasizes stronger focus on relevance, Fair Presentation, and reporting that is less purely compliance-driven. Companies therefore still need to provide an internally coherent story around their material topics.

Fair Presentation: Why the report should be less checklist and more overall picture

A central point in ESRS Set 2 is that it does not just shorten individual requirements, but also shifts the logic behind reporting. This is especially visible in the principle of Fair Presentation.

What does Fair Presentation mean?

A report should not merely appear formally complete. It should provide a coherent, balanced, and understandable overall picture of a company’s material sustainability topics.

In other words, it is no longer enough to simply work through individual Disclosure Requirements. What matters is whether the report as a whole makes it understandable

• which topics are material
• why they are material
• how the company is addressing them

What changes in practice as a result?

With the Simplified ESRS, three things move more strongly into focus:

• Relevance instead of maximum detail
• Coherence instead of isolated individual disclosures
• Clarity instead of overloaded reports

Fair Presentation therefore describes quite precisely what good reporting will increasingly be measured against in the future: not just the quantity of information, but its explanatory value.

Undue Cost or Effort: More pragmatism in data collection

The Undue Cost or Effort principle is intended to reduce the burden on companies wherever data can only be collected with disproportionate effort.

Where is the practical relief?

This is especially relevant for data that is hard to obtain, for example in the value chain or where information cannot be gathered reliably in the short term.

Going forward, there is expected to be more flexibility for:

• estimates
• secondary data
• a more pragmatic approach to data gaps

This is a noticeable relief, especially for companies that are still building reliable ESG data structures.

What does this not mean?

Undue Cost or Effort is not a free pass to simply leave out information.

Companies therefore cannot rely on this principle in a blanket way by saying that data collection is difficult or expensive. What remains decisive is that assumptions, methods, and approaches are transparent and understandable.

What matters here:

• Decisions should be justifiable
• Estimates should be plausible
• Data gaps should be contextualized, not hidden
• the report should still provide a robust overall picture despite simplification

This principle therefore stands for a more realistic approach to data collection. The focus is not on perfection at any cost, but on an approach that remains practical while still being transparent.

Fewer data points, but not automatically lower expectations

Reducing data points is a clear form of relief. According to EFRAG, mandatory data points that must be disclosed when material are expected to decrease by around 61 percent. At the same time, voluntary disclosures will be removed.

What has been reduced in concrete terms?

The simplification mainly affects the volume of disclosures that companies previously had to collect, document, and prepare consistently in addition to core requirements. At the same time, the standards as a whole are expected to become shorter, clearer, and more principles-based. This comes with fewer overlaps, more flexibility in narrative disclosures, and a simplified materiality assessment.

But a reduction of around 61 percent does not mean that sustainability reporting will automatically become 61 percent easier. And it does not mean that companies will only need to prepare a heavily shortened report.

Even with fewer mandatory disclosures, the central task remains the same: companies must transparently explain in the ESG report which topics are material, which information is relevant in that context, and how this results in a coherent report.

What does this mean for companies?

The effort therefore shifts in part:

• away from pure data collection
• toward prioritization, contextualization, and clear presentation

The real simplification, then, is not that everything becomes easy. It is that the focus becomes clearer.

VSME or Simplified ESRS: Decision support for mid-sized companies

With the Simplified ESRS, the question becomes more relevant which framework makes sense for companies that are currently not subject to reporting requirements or want to report voluntarily. VSME is not automatically the better choice simply because it is leaner. What matters is what the reporting is intended to achieve: a pragmatic starting point or voluntary reporting with stronger alignment to ESRS logic.

Answer the following questions for yourself. The more often you answer “yes” to a statement, the more likely the respective standard is a good fit.

VSME is more suitable if …

• You want to start voluntary reporting with the lowest possible effort.
• You need a pragmatic framework without immediately having to work deeply into ESRS systematics.
• Your reporting is primarily intended to provide an initial overview and is not yet meant to reflect all strategic management questions.
• You are still at an early stage when it comes to data, processes, and responsibilities.
• You first want to establish a solid foundation before expanding reporting and management further.

The Simplified ESRS are more suitable if …

• You want voluntary reporting that is already closer to future ESRS logic.
• You want to use sustainability not only for documentation, but also more actively for management and strategic purposes.
• You are already working with a double materiality assessment or plan to do so.
• Your sustainability information also needs to be robust and compatible with expectations from banks, business partners, or more complex customer requirements.
• You want to build reporting today that is more robust and future-proof in the long term.

As a rule of thumb

If you mainly want to get started simply and with minimal use of resources, VSME is usually the more suitable entry point.
If you want to report voluntarily in a more structured way, with greater compatibility and closer alignment to the ESRS, there are stronger arguments in favor of the Simplified ESRS.

* This information is summarized editorial content and should not be construed as legal advice. VERSO accepts no liability.