ESRS Set 1 revision: EFRAG adopts its work plan
Following the mandate received from the European Commission to issue a technical opinion on the simplification of Set 1 of the ESRS, EFRAG delivered its work plan to the Commission on 25 April 2025, 10 days after the initial deadline. The first vote in the Sustainability Reporting Board (SRB) did not achieve the necessary qualified majority, since a number of Board members were waiting for the Secretariat to present more details as to how the deadline of 31 October 2025, which is very tight given the scale of the task, could be met.
The Secretariat’s proposal was therefore revised to produce a work plan based on the following five steps, approved by the Board at the end of April:
- step 1: establishing a vision on actionable levers for substantial simplification of ESRSs (to be confirmed following the stakeholders’ feedback, see below): April to mid-May 2025;
- step 2 (carried out in parallel with step 1): gathering evidence from stakeholders (including via the public consultation launched on 8 April and open until 6 May) and analysis of the reports issued by wave 1 companies: April to mid-May 2025;
- step 3: drafting and approving the exposure drafts amending ESRS: second half of May to July 2025;
- step 4: publishing the exposure drafts, receiving and analysing feedback from stakeholders, including via a public consultation which should last for 30-45 days (this period may be extended, depending on the progress of the ‘Content’ Directive, see the Note in this edition): August and September 2025;
- step 5: finalising and delivering the technical advice to the EC: October 2025.
This work plan departs from the usual EFRAG due process, given the very tight timing imposed by the schedule for the Omnibus I package of proposals tabled by the Commission.
The levers for simplification identified at this stage by EFRAG (to be confirmed in light of the stakeholder feedback) are as follows:
- revising the presentation and architecture, including the articulation of cross cutting and topical provisions. This will include the approach to narrative minimum disclosure requirements on policies, actions, targets and metrics;
- addressing the most challenging provisions: feedback from wave 1 companies will be particularly important. This includes clarification by EFRAG of the application of the materiality principle;
- evaluating possible simplifications to reporting requirements, for example in relation to disclosures on acquisitions/disposals, confidentiality of information, etc.;
- substantially reducing the number of required datapoints, with a (not exclusive) focus on narrative disclosures.
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Tippawan Pumbansao Audit Partner - Bangkok
