What changed in the simplified ESRS, and what didn’t
How to reduce reporting effort using materiality and relief mechanisms
How to structure your CSRD report more clearly and efficiently
How to apply the simplified ESRS in practice, based on your maturity level
When the first companies began preparing their CSRD reports in 2024, one reality quickly became apparent: the initial framework was highly demanding. With more than 1,100 data points to identify, collect, and document, many organisations found themselves overwhelmed by the scope and complexity of the exercise.
In response to this feedback from companies in the field, the European Commission asked EFRAG (the European Financial Reporting Advisory Group) to revise the standards. The objective was clear: maintain the ambition of the CSRD while making the requirements more practical and usable for companies.
The result of this work is the simplified ESRS.
This guide is designed for CSR managers, sustainability directors, CFOs, and their teams preparing for CSRD compliance.
Whether you are just starting your CSRD journey or already well advanced, you’ll find clear analysis of the key changes, along with practical recommendations to help you apply the simplified ESRS effectively.
The simplification of ESRS is a necessary course correction. Wave 1 reporters made clear that the original framework was too heavy for many companies, particularly those without established sustainability systems.
The new approach strikes a more workable balance. It preserves the core of double materiality, while shifting the emphasis from exhaustive compliance to useful disclosure.
Before detailing the changes, let’s remember that the foundations of ESRS remain unchanged.
The simplified ESRS are organized around three major transformations that affect scope, structure, and reporting methods.
The most visible change concerns the volume of requirements to be covered: the number of mandatory data points drops from 1,144 to approximately 450. This massive reduction results from a systematic reassessment of each requirement according to a simple principle: is the information truly useful for understanding the company’s impacts, risks, and opportunities?
Note that there are no longer any “voluntary” data points.
Double materiality analysis (DMA) remains at the heart of the framework, but its execution is simplified. The new framework introduces a funnel approach: companies can now perform preliminary filtering to quickly eliminate clearly non-relevant topics before in-depth analysis.
The simplified ESRS recognize that companies have different communication needs and varying capacities to access data. They therefore offer:
Double materiality analysis is the exercise that determines which sustainability topics you must report on. A well-conducted DMA is your best lever for legitimately reducing your compliance burden.
One of the major contributions of the simplified ESRS lies not so much in introducing radical innovations, but in the explicit clarification of what was previously subject to interpretation. Many companies already applied some of these common-sense practices, but without certainty that they would be accepted during audit. The new text removes these ambiguities.
Many companies had already pragmatically adopted a filtering logic to avoid exhausting themselves on clearly non-relevant topics. But the initial ESRS V1 text left doubt: was this approach compliant? Did you really have to analyze everything in detail?
The simplified ESRS definitively resolve this question by officially endorsing the funnel approach:
Gross vs. net impacts distinction: a new analytical dimension
This dimension is genuinely new in the simplified ESRS. It adds depth to your analysis by distinguishing:
This distinction allows you to consider how effective your management measures are when assessing the severity of your impacts.
For example, a few years ago your industrial site released pollutants into wastewater. You have since taken measures to permanently prevent further leaks. As a result, the actual impact on water pollution has been significantly reduced. You can therefore decide not to include this impact in your double materiality assessment.
One of the recurring criticisms of ESRS V1 was the impossibility of adapting the report structure to the company’s communication needs. The simplified ESRS correct this.
Companies can now add an executive summary at the opening of their sustainability report. This 3-5 page synthesis allows investors, analysts, and executives to quickly understand:
This option is particularly relevant for large companies whose complete report can reach 150 to 200 pages.
Companies can lighten the report body by placing certain information in appendices:
This flexibility allows adapting the level of detail to the target audience while preserving information richness for expert readers.
The philosophical change in General Disclosure Requirements (formerly MDR – Minimum Disclosure Requirements) is one of the most significant in the simplified ESRS.
In ESRS V1, there was some ambiguity around whether companies could state that they did not have a policy on a given topic. That ambiguity has now been removed. The simplified ESRS clearly require companies to disclose, in a clear and straightforward manner, the absence of a policy, action plan, or target where applicable.
The GDR content itself has been lightened. The simplified ESRS remove many details that weighed down reporting without providing significant value.
Example: ESRS V1 required specifying for each policy “the highest organizational level responsible for its implementation.” This requirement disappears in the simplified ESRS.
In ESRS V1, companies often explained the same thing multiple times. On climate for example, different data points separately requested explaining your policy, governance, and strategy, creating unnecessary redundancies.
Now, GDR concentrates almost all qualitative requirements. For each standard, you explain your Policies, Actions, and Targets via GDR, and you then complete this with the qualitative requirements specific to each standard, along with the quantitative metrics.
Redundancies disappear, since you only explain your approach once, in a structured manner.
In summary, changes to GDR bring three major benefits:
It’s sometimes very complicated to obtain certain data, particularly those concerning the value chain. EFRAG has therefore implemented mechanisms to simplify reporting of this data.
Definition
This principle allows omitting a data point when obtaining it requires disproportionate cost or effort relative to the company’s size and means.
Application conditions
Use isn’t free. The company must document:
A company must report Scope 3 emissions from 500 suppliers. Obtaining primary data would require recruiting a dedicated person for 18 months.
Solution:
Definition
This mechanism allows you to report a metric only for the part of your scope where it is genuinely material, without having to cover all of your operations if doing so does not add value.
Application conditions
The company must:
You are a group with 10 industrial sites and 20 administrative offices. Your water consumption is concentrated in your manufacturing sites (cooling processes, industrial cleaning), while your offices only use sanitary water, which is negligible.
Solution using a partial scope:
No extension roadmap required: the relevant scope is already fully covered
Two categories benefit from an extended deadline:
This delay allows progressively developing capabilities rather than producing unreliable estimates from the first year.
The simplified ESRS introduce an explicit principle of “fair presentation” that guides the use of relief mechanisms and overall reporting quality.
Your report must reflect your reality faithfully, in a balanced and understandable manner. This principle places information quality and honesty above formal compliance.
Concretely, this means:
Contextualize your data
Don’t just provide raw figures. Explain trends, underlying actions, factors influencing your results.
Be transparent about your limitations
Clearly indicate which data is missing, why, and when you plan to obtain it. Honesty about your gaps is valued.
Present in a balanced way
Show your progress AND your challenges. A report presenting only successes lacks credibility.
Avoid greenwashing
Don’t exaggerate your positive results, don’t omit your negative impacts, don’t hide your difficulties behind technical jargon.
Facilitate understanding
Use clear language, graphics, concrete examples. Information must be accessible.
| Aspect | ESRS V1 | Simplified ESRS |
| Mandatory data points | 1,144 | ~450 (-61%) |
| Voluntary data points | Present | Removed |
| DMA – Preliminary filtering | Implicit, subject to interpretation | Explicitly authorized and clarified |
| Report structure | Rigid | Flexible (summary, appendices) |
| PAT | Mandatory | Only if existing |
| Redundancies | Same qualitative data points in multiple places | Centralized in GDR |
| Relief mechanisms | Limited | Expanded (undue cost or effort, partial scope) |
| Phase-in | Until 2026 | Until 2029 |
| Fair Presentation | Implicit | Explicit principle |
Climate remains a priority with high requirements, but three important adjustments are introduced.
Change 1: GHG emissions scope
Emissions must now be reported according to financial control (not operational). An entity is included in your carbon scope if it’s consolidated in your accounts. This change aligns carbon reporting with financial reporting, facilitating consistency and reducing double-counting risks.
Change 2: Exemption for financial institutions
Banks, insurers, and asset managers are no longer required to publish the absolute value of their reduction targets for Scope 3.15 (emissions from investment and loan portfolios). Carbon intensity reporting (tCO2e per €M invested, for example) suffices, making figures more comparable and relevant.
Change 3: Phase-in
Phase-in until 2029 for anticipated financial effects of climate change, allowing progressive capacity building in modeling.
Three significant simplifications on this standard.
Simplification 1: Phase-in on hazardous pollutants
“Substances of Concern” (hazardous substances) can be reported progressively:
Simplification 2: Disappearance of financial effects calculation
The obligation to calculate financial effects of environmental risks linked to pollution disappears, considerably lightening the analytical burden.
Simplification 3: Simplified KPIs
Indicators on microplastics and certain pollutants are simplified, with lightened reporting requirements.
Pas de modifications structurelles majeures, à l’exception de la disparition du calcul des effets financiers (comme pour E2)
New definition: adequate wage
Based on ILO principles, this definition specifies that an adequate wage must cover the worker’s and their family’s essential needs (housing, food, health, education). This clarification applies to all countries, including in the EU.
Practical application: Compare wages paid with available “living wage” references (Global Living Wage Coalition), measure gaps, explain your actions to close them.
Major simplification: stakeholder interactions
Publication requirements around stakeholder interactions are simplified. You no longer have to exhaustively detail each consultation process.
Simplification of remediation means
Requirements concerning means of remedying negative impacts (complaint mechanisms, remediation processes) are also lightened, with focus on essentials: existence, accessibility, and results.
Three major developments on this standard.
Development 1: Structure harmonization
The G1 standard structure is reorganized to harmonize with other environmental and social standards. This consistency facilitates navigation and understanding.It’s now very clearly established that you must rely on GDR (formerly MDR) to describe your business conduct strategy: Policies, Actions, Objectives. This clarification removes any ambiguity about how to structure information.
Development 2: Simplifications on corruption
The qualitative requirements focus on prevention: anti-corruption policies, training, detection systems, and due diligence on business partners. Fewer quantitative data points are now required: the obligation to report confirmed corruption incidents has been removed.
Development 3: Simplifications on payments
Reporting now focuses on payment terms to SMEs (no longer all suppliers), addressing a real social and economic issue. Report: average SME terms, percentage of invoices paid on time, improvement actions.
Not all companies approach CSRD with the same maturity level. That’s why you’ll find three roadmaps adapted to your situation: beginner, intermediate, and advanced.
You’re in this situation if:
🎯 Objective: Lay foundations
Don’t aim for exhaustiveness. If a topic is clearly not relevant, exclude it.
Your objective: identify the 5–7 most critical topics.
Don’t aim for exhaustiveness. If a topic is clearly not relevant, exclude it.
Your objective is to identify 5–7 truly material topics, not 15.
“We are at the beginning of our CSRD journey. Here is what we have implemented, here is what is still missing, and here is our plan to improve.”
Key actions:
Timeline summary – Beginner Profile
| Period | Phase | Key actions | Duration | Main deliverable |
| Q1-Q2 2027 | Preparation | Team, training, assessment, structural decisions | 3-4 months | Project plan + budget |
| Q2-Q3 2027 | Materiality analysis | Preliminary filtering, IRO analysis, | 3-4 months | Materiality matrix + relief plan |
| Q3-Q4 2027 | Data collection | Templates, collection, gap documentation | 3-4 months | ESG database |
| Q4 2027 – Q1 2028 | Writing | GDR, data points, fair presentation | 2-3 months | Draft report (40-70 pages) |
| Q1 2028 | Audit & publication | Internal review, external audit, corrections, publication | 2-3 months | Published report |
Total duration: 13-18 months
Recommended starting point: January 2027
Publication: Spring 2028
Your 2028-2030 progression plan:
| Year of publication | Maturity | Focus |
| 2028 (on FY 27)) | Initiation | Relief at maximum, transparency about gaps, processes established |
| 2029 (on FY28) | Development | Scope extension to 70-80%, data quality improvement, first policies |
| 2030 (on FY29) | Consolidation | Full compliance expected, reduced relief, established processes |
You’re in this situation if:
Your philosophy: Optimization and adjustment
Objective: Take advantage of simplifications
Key actions:
Deliverable:
Objective: Strengthen what exists
Key actions:
Collection focus: Focus your data collection efforts on the most material activities and scopes for each metric. Use partial scope reporting to start with your priority sites, suppliers, or activities, then expand progressively.
Objective: Quality and readability
Key actions:
Target structure: Improve the readability of your report by opening with an executive summary and placing methodological details in appendices. This makes the report accessible to different audiences, including investors, auditors, and other stakeholders.
Deliverable:
Key actions:
Timeline summary – Intermediate Profile
| Period | Phase | Key actions | Duration | Main deliverable |
| Q1 2027 | Strategic review | DMA revision, collection reassessment, structure adjustment | 1-2 months | Revised DMA + optimized plan |
| Q1-Q2 2027 | Collection improvement | Collection finalization, automation, gap filling | 2-3 months | Consolidated database |
| Q2-Q3 2027 | Optimized writing | GDR, executive summary, appendices, fair presentation | 2-3 months | Draft report (70-120 pages) + summary |
| Q4 2027- Q1 2028 | Audit & publication | Review, audit, publication | 2-3 months | Published report |
Total duration: 7-11 months
Recommended starting point: January 2027
Publication: Spring 2028 (mandatory)
Your 2027-2029 progression plan:
| Year | Maturity | Focus |
| 2028 | Optimization | Relief on 30-40% data points, optimized processes, improved narrative |
| 2029 | Reinforcement | Scope extension to 80-90%, strengthened policies, reduced relief |
| 2030 | Maturity | Full compliance, established excellence, continuous improvement |
You’re in this situation if:
Your philosophy: Excellence and leadership
Objective: Be ahead of the curve
Key actions:
Benefits:
Objective: Transform compliance into strategic tool
Key actions:
Objective: Stay at the forefront
Key actions:
Use of relief: Even advanced, you can use relief on residual complex topics. Document your improvement roadmap to show your commitment.
Key actions:
Timeline summary – Advanced Profile
| Period | Phase | Key actions | Duration | Main deliverable |
| Q3-Q4 2026 | Voluntary application | Decision, DMA revision, simplification integration | 3-4 months | Validated voluntary strategy |
| Q4 2026 – Q1 2027 | Narrative excellence | Executive summary, thematic organization, fair presentation | 2-3 months | Premium draft report (100-150 pages) + summary |
| Ongoing | Continuous improvement | Fill residual pockets, automation, anticipation | Ongoing | Reinforced maturity |
| Q1-Q2 2027 | Publication & communication | Audit (reasonable assurance), early publication, communication | 1-2 months | Published report + communication |
Total duration: 6-9 months
Recommended starting point: Summer 2026
Publication: April-May 2027 (voluntary FY26 application)
Your 2027-2029 plan:
| Year | Maturity | Focus |
| 2027 | Leadership | Voluntary application, narrative excellence, refined processes |
| 2028 | Excellence | Continuous improvement, last relief reductions |
| 2029 | Complete maturity | Reporting innovation, sectoral influence, regulatory change anticipation |
Regardless of your profile, certain points deserve particular attention.
Why it’s crucial: It’s your best lever to legitimately lighten your burden. A rigorous and well-documented DMA will be easier for your auditors to review and verify.
Points of vigilance:
Why it’s crucial: Poorly documented, they can be rejected at audit. Well documented, they’re your safety valve.
Points of vigilance:
“Undue cost or effort”:
Partial scope:
Phase-in:
Why it’s crucial: It’s your report’s guiding thread. A faithful and balanced report is more credible than a “perfect” report hiding difficulties.
Points of vigilance:
Why it’s crucial: Your sustainability report must be consistent with your management report and financial statements.
Points of vigilance:
Focus on what’s material
Run your double materiality assessment with CSRD-ready workflows. Set thresholds so your report highlights only the ESG topics that matter most.
Spot and close data gaps
Map every required datapoint, flag missing information, and automate data collection across teams and value chain partners.
Enable cross-functional collaboration
Make it easy for finance, HR, legal, procurement, and operations to input, validate, and track ESRS data in one place.
Track readiness in real time
Use dashboards to see progress, identify strong coverage, and spot gaps across material topics and ESRS sections.
Simplify audits and assurance
Rely on validation checks, approval flows, and audit trails. Lock disclosures with data snapshots to prepare for external review.
Turn compliance into value
Use CSRD and ESRS data to set targets, model scenarios, and drive transition plans that deliver ROI and accelerate progress toward net zero.
Sweep is a carbon and ESG management platform that empowers businesses to meet their sustainability goals.
Using our platform, you can:
