EFRAG Outreach Session: Key Takeaways on Revised ESRS Exposure Drafts

Sodali & Co joined the EFRAG public outreach event in Brussels on September 24 to provide feedback on the Revised ESRS Exposure Drafts published earlier in July. The session is part of a wider series of EFRAG public outreach events complementing the public consultation survey open until September 29 aiming to refine the standards for better manageability under the CSRD. Attendees including representatives from business associations, financial institutions, investors, and civil society discussed amendments focused on burden reduction while maintaining alignment with the objectives of the CSRD.

Key Takeaways

Positive Feedback on Readability
Stakeholders unanimously commended the agile approach and significant improvements in the ESRS drafts. The revised structure prioritizes conciseness, adopting a more principle-based system, eliminating overlaps between general disclosures and topical standards, and removing all "may" voluntary requirements. This has resulted in a 49% reduction in the overall length of the standards, enhancing readability for preparers.

Support for 57% Reduction in Mandatory Datapoints, with Questions on Burden Relief
The 57% reduction in mandatory datapoints (from 803 to 347, if material) was broadly supported as a step toward lighter reporting requirements. However, some noted that this may not proportionally reduce effort, as remaining datapoints still demand significant data collection and analysis. Stakeholders called for further field testing to assess the true impact on reporting burden.

Consensus on Need for Seamless Interoperability with Global Standards
All participants stressed the critical need for enhanced interoperability with ISSB standards to minimize cross-jurisdictional burdens for global companies. The revised drafts align wording, share reliefs for undue cost or effort, and harmonize climate disclosures in ESRS E1. Stakeholders urged further refinement of remaining differences to ensure comparable data for investors and preparers.

Focus on Gross vs. Net Impacts in Double Materiality Assessment (DMA)
The new guidance on gross vs. net impacts in the DMA process focuses on residual impacts after mitigation, remediation, or prevention measures, with some illustrative examples. Stakeholders welcomed the practical guidance but sought greater clarity on how this integrates with the main text, advocating for a more principle-based approach to simplify impact assessments.

Emphasis on Anticipated Financial Effects for Investors
The revised ERS streamline anticipated financial effects while removing them from other environmental standards due to underdeveloped methodologies. Investor representatives emphasized these disclosures are critical for transparency and assurance in investment decisions, as well as supporting SFDR data needs. The revised ESRS will need to strike a careful balance between ensuring transparent disclosure and acknowledging that, in certain areas, methodologies for assessing anticipated financial impacts remain underdeveloped.

Flexibility Sought in GHG Reporting Metrics and Control Boundaries
On ESRS E1 climate disclosures, representatives from financial institutions advocated for greater flexibility in GHG emissions reporting, particularly around absolute Scope 3 emissions disclosures, favoring intensity-based metrics that align with their target-setting practices. Stakeholders broadly supported maintaining options between operational and financial control boundaries to accommodate diverse business models.