Omnibus I and ESRS simplification: analysis of EFRAG’s technical advice on the draft simplified standards

On 3 December 2025, the European Financial Reporting Advisory Group (EFRAG) officially submitted its technical advice to the European Commission regarding the simplified draft of the European Sustainability Reporting Standards (ESRS). In a regulatory context where sustainability reporting is rapidly evolving, our experts have analysed it to highlight the main changes compared to the previous Set 1.

The analysis outlines an overview of the main changes proposed by EFRAG, to reduce companies’ reporting burden, as requested by the Commission, with simplifications both by overall lever, as well as by individual standards. The analysis distinguishes between EFRAG’s new proposals, not yet applicable to 2025 reports published in 2026 and clarifications of Set 1, which wave 1 companies may find useful to consider for year-end reporting. 

What changes

The simplifications proposed by EFRAG bring significant changes to Set 1 and are structured around six levers to address the complexities encountered by wave 1 companies when implementing the ESRS:  

  • Simplification of the materiality assessment.  
  • Better readability and conciseness of the sustainability statements.  
  • Critical modification of the relationship between general disclosures and topical standards.  
  • Improved understandability, clarity and accessibility of standards.  
  • Introduction of burden-reduction reliefs.  
  • Enhanced interoperability with generally accepted reporting standards or frameworks.  

The new standards should therefore result in clearer reporting, with a stronger focus on information that is truly decision useful for users.  

In practice, these proposals reduce the number of mandatory datapoints (DPs) by about 60%. The draft simplified standards also no longer contain any voluntary DPs, reducing the length of the standards by more than half. However, companies will still need to carefully assess to what extent the ESRS Set 2 will ease their preparation of sustainability statements, as the reduction in the number of DPs will not likely translate into a proportional decrease in reporting burden. 

Next steps

The Commission will now follow its own due process and launch consultations based on this technical advice, once the legislative process to amend the Corporate Sustainability Reporting Directive (CSRD) has been completed.The adoption of a new delegated act on ESRS (Set 2), replacing that of July 2023 (Set 1), is therefore expected to be adopted in mid-2026.  

When the revised CSRD comes into effect, this new set of standards will become mandatory for preparing the 2027 sustainability statements to be published in 2028. Early application starting from 2026 reporting should be possible but remains to be confirmed.  

How we can help

Our objective is to help you anticipate the changes introduced by EFRAG’s proposals, assess their impact on your reporting processes and ensure compliance. Thanks to active and rigorous monitoring, we can provide precise tracking of the delegated act that will endorse the final revised standards in 2026. 

At Forvis Mazars, we have already assisted many clients on ESRS implementation and sustainability reporting, staying involved across all key steps to ensure a robust and dependable outcome.  

Download the guide

To explore our experts’ insights, download the full guide below. 

Document

Omnibus I and ESRS simplification: deep dive into EFRAG’s technical advice on the draft revised standards

Our experts