Eurosif feedback on ESRS Set 1 review
As part of the European Commission’s Omnibus 1 proposal, aimed at streamlining EU sustainability rules, EFRAG has been tasked with simplifying the European Sustainability Reporting Standards (ESRS).
To gather input from organisations that have been applying the standards, and from any other relevant stakeholders, EFRAG opened a call for feedback in April 2025, in the form of an online questionnaire.
Eurosif responded to the questionnaire after consultation with its network, providing the perspective of investors.
Our priorities:
Safeguarding the progress achieved
- The ESRS makes a significant contribution to facilitating investors’ capital allocation in line with their clients’ preferences, to channel investment towards the green transition and to manage their own exposure to risks and impacts.
- The ESRS includes the double materiality perspective and environmental (climate, biodiversity, circular economy, and other), social, and governance information. This is particularly important to enable the reporting of reliable and comparable data and should be maintained.
- Investor feedback from the first reporting wave indicate improved alignment and consistency in fundamental metrics, providing investors with more comparable, decision-useful information.
Keeping vital information
- The Climate disclosures as outlined in ESRS E1 are well-aligned with other standards (ISSB/GRI, CA 100+ or TPT) and offer little to no room for further streamlining. To maintain relevance, these data points should remain as they are.
- For investors, forward-looking information such as climate transition plans, is highly valued and must be maintained, including assessment of the plans and targets.
- Information that is linked to other pieces of EU regulation, including but not limited to the Sustainable Finance Disclosure Regulation or the Benchmark Regulation, is important for investors to fulfil their own obligations.
- While some narrative datapoints offer room for streamlining and simplification, they serve an important function of contextualising quantitative datapoints and covering areas that do not amount to numerical values.
- Our response includes examples of vital datapoints. Please note that these lists are not comprehensive, our work on compiling essential datapoints for investors is still ongoing.
Targeted adjustments rather than fundamental changes
- Help companies assess and disclose what is material for them and investors by clarifying the double materiality assessment process and through sector-specific guidance, on the basis on the existing work on the sector-specific standards.
- Remove duplications between cross-cutting and sectoral standards.
Work In Progress:
We are continuing to consult our members, their members and our Eurosif Club partners to develop a list of essential data points for investors. This work is one of the priorities of our Sustainability Data Advisory Group (SDAG).
Find Eurosif’s position on the Omnibus 1 package here.
